UnscheduledTransfer Pricing: Intangibles and Intra-Group Finance

This course provides participants with an in-depth coverage of two of the critical areas of transfer pricing currently under discussion at the OECD, amongst tax scholars and practitioners, and between tax administrations.
 
Please note: This course is currently not scheduled. The price, program and instructors’ details are taken from the previous course. They are included here for information purposes only and may be subject to change.
Type:
Open Course
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Intermediate
Course code:
OC12TPIF1
Price:
€ 1,943 / $ 2,428 (VAT excl.)
IBFD Members:
Members receive a 20% discount
 
Early Bird Discount: a 30% discount will be applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
 
Transfer Pricing: Intangibles and Intra-Group Finance

Overview and Learning Objectives

This course provides participants with an in-depth coverage of two of the critical areas of transfer pricing currently under discussion at the OECD, amongst tax scholars and practitioners, and between tax administrations. Both intra-group finance and intangibles raise a range of complex transfer pricing considerations, and if not adequately addressed may expose a multinational to significant transfer pricing risk. The course incorporates practical examples and case studies, aimed at consolidating knowledge obtained from the formal lectures.
 
This is an interactive course with a maximum of 30 participants. Prior to the course, participants will be given access to a documentation platform which provides them with additional pre-reading material and supplementary material (e.g. legal documentation, case law and related articles/literature). During the course, participants will be provided with a course binder containing documents relevant to the course.


Who Should Attend? 

The course is suitable for transfer pricing advisers, lawyers, accountants, tax inspectors, and in-house transfer pricing managers. The course will enable participants with a good understanding of basic transfer pricing principles to gain an in-depth understanding of, and learn how to manage, transfer pricing issues.


Course Level and Prerequisites 

This is an intermediate-level course. Participants taking this course will be expected to have a good understanding of transfer pricing principles. 
 

Pre-course Preparation 

In order to participate in this particular course, no advance preparation is necessary. However, for some courses, suggested reading materials will be made available on our documentation platform a few weeks before the start of the course. 
 

Interactive Course - "Group Live"  

To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 30 participants will be accepted. Early registration is therefore recommended.


Continuing Professional Education 

Recommended CPE points for this course: 17,5 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for ITA courses.
 

Course Fee and Registration Details 

The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
 

 

  • The significance of intangibles in transfer pricing
  • Identification and classification of intangibles
  • Transfer Pricing of Intangibles
  • Cost Contribution Agreements
  • Cost Sharing Agreements: overview of the US regulations
  • Transfer pricing and Intra-Group finance: a growing area of controversy
  • Inter-company loans
  • Cash Pooling
  • The interaction of Transfer Pricing and Thin-Cap
  • Foreign exchange and derivatives
  • Summary Session: Developing a Financial Transaction Policy 
  • Michel van der Breggen
    Michel van der Breggen is a partner in the Transfer Pricing Group of PwC. He studied Tax Law at the University of Leiden and...
  • Chris Demetrius
      Chris Demetrius is a consultant in the Financial Services Transfer Pricing Group of PwC. He has a Business and Finance...
  • Monica Erasmus-Koen
    Monica Erasmus-Koen is a tax senior manager at PwC in the Dutch Transfer Pricing practice. She started out with an audit...
  • Clive Jie-A-Joen
      Clive Jie-A-Joen is the senior economist of Ernst & Young’s transfer pricing & tax effective supply...
  • Antonio Russo
    Antonio Russo is a Partner with Baker & McKenzie Amsterdam’s Transfer Pricing Team, which has been awarded the...