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07 - 11 Oct 2019Principles of Transfer Pricing

This transfer pricing course focuses on major transfer pricing issues and concerns that all professionals involved in transfer pricing will face.
Tax Courses
Amsterdam - The Netherlands
Course code:
EUR 3,059 / USD 3,671 (VAT excl.)
Client offer:
20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Early Bird Discount: a 30% discount will be automatically applied for registrations received 60 days or more before the commencement of the course (cannot be used in conjunction with other discounts).
This course is expected to sell out. We also already accept registrations for the next run, taking place 09 - 13 March 2020, via this link.
Principles of Transfer Pricing

Overview and learning objectives

On 5 October 2015, the OECD published its reports addressing base erosion and profit shifting (BEPS). This new guidance can be considered a game changer and is expected to alter the transfer pricing outcomes in many situations. This requires a different approach from both tax authorities and multinational enterprises. A significantly more granular risk and functional analysis should be performed. Companies as well as tax authorities need to have a better understanding of how value is created with respect to the development and exploitation of their intangibles. A further point of focus is the way in which companies and tax authorities should deal with the three-tiered OECD approach related to transfer pricing documentation.

In order to deal with all developments in the field of transfer pricing properly, it is essential to fully understand the transfer pricing principles and methodologies and their practical application. This five-day intermediate-level course introduces participants to such principles and methodologies and then covers their application to specific categories of intra-group dealings. The theoretical sessions are complemented by case studies.


This course serves as good preparation for the CIOT's ADIT Paper III - Option F. For more information about the Advanced Diploma in International Taxation you can visit the CIOT’s website.

This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.

Field of study


Who should attend?

The course is suitable for finance and tax personnel of multinational enterprises, tax accountants, economists and lawyers, in-house tax managers, tax and transfer pricing advisers, and government officials and tax officers.

Course level and prerequisites

This is an intermediate level course, containing introductory sessions. Whilst prior experience of transfer pricing is desirable, it is not a prerequisite to satisfactorily participate in this course.

Pre-course preparation

In order to participate in this particular course, no advance preparation is necessary. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks.

Interactive course - "Group Live" 

To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 32 participants will be accepted. Early registration is therefore recommended.

We invite you to send us in advance any technical, content-related questions you may have. During the course we will try to address your specific questions, but please note that this will depend on the amount of time available, the relevance of the questions and the order in which the questions are received.
Should you have a question, please send it to

Disclaimer: The information provided during the course has been prepared solely for the instruction of course participants. This information is not intended to constitute advice on any particular matter.

Continuing Professional Education

Recommended NASBA CPE points for this course: 32 (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 IBFD International Tax 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.

  • Introduction to transfer pricing
  • Comparability analysis
  • Transfer pricing methods
  • Intra-group services and cost contribution arrangements
  • Transfer pricing and intangibles
  • Intra-group finance transactions
  • Business restructuring
  • Permanent establishments
  • Transfer pricing documentation
  • Administrative approaches to avoiding and resolving transfer pricing disputes
  • Managing the customs-transfer pricing nexus
  • Transfer pricing risk management
  • Case studies
  • Antonio Russo is Partner (Economist) with Baker & McKenzie and heads the Amsterdam Transfer Pricing Team, which has been awarded the International Tax Review Award for The Netherlands Transfer...
  • Sharvari Kale is a Senior Associate in the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam, the Netherlands. She is responsible for editing transfer pricing publications and...
  • Frank Schneider is a Transfer Pricing Senior Manager working for SABIC. He has worked across four countries in the world of tax and transfer pricing and has a mix of in-house and advisory...
  •  Erik Jan van Sten
    Erik Jan van Sten has been a transfer pricing professional since 1999. Prior to joining Shell in 2009, Mr Van Sten was a transfer pricing consultant in private practice. As a member of Shell’...
    Ágata Uceda is director with the transfer pricing team of KPMG Meijburg & Co. She has 15 years of experience working in the transfer pricing field and advises multinationals on a variety...
  • Picture Michel van der Breggen
    Michel van der Breggen is a partner in the Dutch transfer pricing practice of PwC. He joined the firm’s corporate tax practice in 1996 after obtaining a tax law degree from Leiden University...
  • Bo Wingerter
    Bo Wingerter is a member of EY’s Transfer Pricing and Operating Model Effectiveness (OME) group in Amsterdam, the Netherlands. He recently spent a couple of years working for EY in the...
  • Hans Pijl has Linguistics (MA) and Law (LLM) degrees from the University of Leiden, the Netherlands. He is an independent tax lawyer and was until recently of counsel to Deloitte in matters...
  • Eduard Sporken is a Director of KPMG Meijburg & Co in Amsterdam and a member of KPMG Meijburg & Co’s Dutch and Global Transfer Pricing Services/Value Chain Management and Global...
  •  Brian Mulier
    Brian Mulier is a partner in the International Tax and International Trade & Customs Practice Group of Bird & Bird LLP and is based in The Hague. He has extensive experience in advising...
  • Marc Kanter 
    Marc Kanter is a Transfer Pricing Director at AkzoNobel, the Netherlands. He joined AkzoNobel in 2017 and is involved in the management of all transfer pricing-related issues, including dealing...