After reading an email from the Tax Executives Institute (TEI) Case Competition organizers, confirming that the University of Waterloo team had been selected as one of the two Canadian teams for the second edition of this international tax competition, I found myself asking, “What is transfer pricing?” I vaguely remembered having come across ‘Transfer Pricing’ at some point within my previous co-op placements, but never found the opportunity to sit down and truly explore what it is. To my team’s relief, which consisted of myself (AFM), Leah (MAcc), Natalie (MAcc), and Audrey (Math/CPA), the organizer partnered with the International Bureau of Fiscal Documentation (IBFD) to provide competitors with access to an online course that helped teach us about transfer pricing.
However, some things do not happen as simply as we want them to; because the concept of ‘Intangible Properties’ was thrown into the mix. Accountants regularly come across ‘intangible assets’ in certain financial statements – but I never thought much about how intangibles are determined as intangibles for tax purposes. So, we gathered that the theme would be “Transfer Pricing of Intangible Properties.”
It should be straightforward, right? Wrong. Let’s account for the fact that transfer pricing happens on an international scale. Translation: each country has its own definition of intangibles and their own tax rulings – if they have any. Additionally, transfer pricing usually happens across different countries. Keeping all this in mind, the main complexity is that some businesses in higher-taxed countries ‘move’ their operations to lower-taxed countries; you get the gist.
Overall, I found that this topic was challenging. Thankfully, my team had been assigned two exceptional mentors by TEI who were transfer-pricing experts – which is a niche in the niche that already is tax. And to top it off, we formed the only all-women team (students and mentors) in this competition!
What I enjoyed the most about this competition was that it was an enriching opportunity to explore the intersection of tax and law. It helped shed more light on why tax practitioners usually tend to work together with lawyers. Did I forget to mention that the other teams came from Argentina and America? This diversity in background, considering that some student teams majored in law, gave me great insight into the different ways of approaching a situation like this.
My biggest takeaway from this experience is the reminder to stay open-minded and learn new concepts – the learning never ends, even as I reach the end of my undergraduate studies.