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Paper 3.03: Thematic Module (Transfer Pricing Option)

In thematic module, we are offering the most demanding subject that is Transfer pricing. The module covers the fundamentals of transfer pricing based on the OECD model. The module will focus on transfer pricing methods, the arm’s length principle, comparability, compliance issues and avoiding double taxation and dispute resolution. The exam consists of three parts.

  1. 1. Part A consists of two mandatory questions worth 25 marks each.
  2. 2. Part B consists of two questions worth 20 marks each, of which candidates are required to answer one.
  3. 3. Part C consists of five questions worth 15 marks each, of which candidates are required to answer any two.

This exam is offered in the June and December exam sessions.

Topics to be examined Weightage
Fundamental sources 15%
The arm’s length principle (ALP) 5%
Functional analysis 10%
Transfer pricing methods 10%
Comparability 10%
Specific transactions 15%
Permanent establishments (PEs) 10%
Compliance issues 5%
Avoiding Double Taxation and dispute resolution 10%
Other issues 10%

* These exams are available in both June and December attempt, while remaining only in June attempt.

** Extended essay in place of one of the optional (Paper II and Paper III) exams, candidates may submit an extended essay consisting of 15,000 to 20,000 words on any aspect of international taxation (subject to approval).

The mode of attempting the exam is on-screen only which means students can attempt the exam by typing their answer on-screen, using purpose-built software on their laptop.