LL4AZ      Half Unit
Taxation of Multinational Enterprises: Transfer Pricing

This information is for the 2023/24 session.

Teacher responsible

Eduardo Baistrocchi


This course is available on the LLM (extended part-time), LLM (full-time) and University of Pennsylvania Law School LLM Visiting Students. This course is available with permission as an outside option to students on other programmes where regulations permit.


This course has a limited number of places and demand is typically high. This may mean that you’re not able to get a place on this course.

Course content

The course offers a comprehensive introduction to the taxation of multinational enterprises, focusing on transfer pricing. It offers both theoretical and practical understanding of the fundamentals of this core topic of international taxation. The course will begin with an overview of the transfer pricing issue, including its history, current importance and global trends. General concepts, special rules and the different types of transfer pricing transactions will be discussed. Finally, the course will provide a review of transfer pricing controversy in a number of jurisdictions, including G20 countries and tax hubs such as Ireland and Luxembourg.


This course will have 20 hours of teaching content in Winter Term and two additional hours of teaching in the Spring Term. There will be a Reading Week in Week 6 of Winter Term.

Formative coursework

Students will have the option of producing a formative essay of 2,000 words.

Indicative reading

Detailed reading lists will be provided during the course via Moodle.

Sample readings include:

Báez, Andrés and Brauner, Yariv, Taxing the Digital Economy Post BEPS ... Seriously (March 1, 2019). University of Florida Levin College of Law Research Paper No. 19-16, Available at SSRN: https://ssrn.com/abstract=3347503 or http://dx.doi.org/10.2139/ssrn.3347503

E. Baistrocchi, Article 9: Associated Enterprises — Global Tax Treaty Commentaries, Global Tax Treaty Commentaries, International Bureau of Fiscal Documentation, 2022. Available at: https://www.ibfd.org/news/global-tax-treaty-commentaries-gttc

E. Baistrocchi, ‘Transfer Pricing Dispute Resolution: The Global Evolutionary Path’ in E. Baistrocchi and I. Roxan (eds.), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press). Available at SSRN: https://ssrn.com/abstract=2337717


Exam (100%, duration: 2 hours, reading time: 15 minutes) in the spring exam period.

Key facts

Department: Law School

Total students 2022/23: 10

Average class size 2022/23: 10

Controlled access 2022/23: Yes

Value: Half Unit

Guidelines for interpreting course guide information

Course selection videos

Some departments have produced short videos to introduce their courses. Please refer to the course selection videos index page for further information.

Personal development skills

  • Communication
  • Specialist skills