During this course, you will deal the conceptual problems and limitations of the design of the arm's length principle (ALP) and the OECD Transfer Pricing Guidelines (OECD TPG). In this respect, the students attending the class are expected to have the knowledge and understanding of the current rules and objectives of the ALP in order to make a step further and analyze where and why the ALP rules and OECD TPG fail to deliver the expected results. The course will be relevant for critical out-of-the-box thinkers who do not only rely on the rules as they are but who take or would like to take an active role in impacting the tax policy design in transfer pricing and profit allocation matters.