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28 - 29 May 2020Transfer Pricing and Intra-Group Financing

This course addresses transfer pricing issues related to intra-group financing transactions. Theory will be demonstrated through examples and case studies. A tax director of an MNE will share his/her best practices.


Tax Courses
Amsterdam - The Netherlands
Course code:
EUR 1,853 / USD 2,224 (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).
Transfer Pricing and Intra-Group Financing

Overview and learning objectives

This course addresses transfer pricing issues related to intra-group financing transactions. On 11 February 2020, the OECD released its final report with transfer pricing guidance on financial transactions. Over the last couple of years, countries have implemented more detailed transfer pricing legislation and guidance, while companies have tried to ensure that their cross-border intra-group product flows, royalties and management charges are set on an arm’s length basis and are fully documented. Unfortunately, the same cannot always be said for intra-group financing and the provision of treasury services. These issues are, however, of the utmost importance given that (i) the OECD issued its transfer pricing guidance on financial transactions, (ii) intra-group financing arrangements now form a key part in the transfer pricing Master File in the 2017 OECD Transfer Pricing Guidelines, and (iii) changes at the UN and EU level are also to be taken into consideration. In light of the increase in information transparency, these arrangements now need to be properly supported and documented. Currently, tax authorities are focusing on the application of the arm’s length principle to these transactions and growing awareness in this respect is to be expected.

This course provides participants with the confidence and practical understanding they need in the field of transfer pricing and intra-group financing. The course is aimed at giving participants insight into and deepening their knowledge of, for example, changes in market circumstances, setting up an efficient treasury function, the latest developments with respect to the OECD guidance, hybrid financing, guarantees and cash pooling. Although the course will deal with real-life cases, domestic legislation will not be addressed in specific detail.

Field of study

Who should attend?
The course is suitable for transfer pricing advisers, lawyers, accountants, tax inspectors, in-house tax and transfer pricing managers and directors and treasury managers.

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.

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.

Continuing Professional Education
Recommended NASBA CPE points for this course: 13.5 (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 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.

  • Transfer pricing and intra-group finance: an area of growing controversy
  • Treasury function within an MNE
  • Intercompany loans
  • Cash pooling
  • Guarantees
  • Case study
  • Recommendations
  • 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...
  • Andre Dekker works as a transfer pricing economist with the Baker & McKenzie’s Amsterdam Transfer Pricing team. His main area of focus is intercompany finance transactions and valuation...
    Rezan Ökten is Transfer Pricing counsel at Houthoff in the Netherlands. He has in-depth transfer pricing knowledge and experience in the technology and telecommunications industry and has...
    Omar Moerer, CFA, is a Director with PwC’s Transfer Pricing Team. Mr Moerer advises clients on transfer pricing matters ranging from design to implementation and from documentation to...
    Krzysztof Łukosz is a transfer pricing senior manager at Ernst & Young in Amsterdam. He has been specializing in transfer pricing services since 2007, with the main area of his expertise...
  • Francesco Iaquinto
    Francesco Iaquinto is a Transfer Pricing Specialist for Nationale Nederlanden (NN) and has over eight years of relevant experience. His specialization addresses the economic aspects of transfer...
  • Mark Drenth
    Mark Drenth is Senior Manager Treasury Operations at Liberty Global in the Netherlands. He has worked in the Corporate Treasury department since 2009, in which capacity he has gained a wide...