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UnscheduledTransfer 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.

 

 
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:
Tax Courses
Language:
English
Location:
Amsterdam - The Netherlands
Level:
Intermediate
Course code:
OC18TPIF1
Price:
-
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. 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 intra-group financing arrangements now form a key part in the transfer pricing master file under the OECD BEPS recommendations, and 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.

Field of study
Taxes

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...
  • Alejandro Zavala Rosas
    Alejandro Zavala is a transfer pricing economist at Baker McKenzie’s, Amsterdam. Prior to joining the European transfer pricing team in 2015, he was part of the firm’s Mexican transfer...
  •  Rezan Ökten
    Rezan Ökten is Global Transfer Pricing Manager at VEON in the Netherlands. With over ten years of dedicated transfer pricing experience, he is responsible for the development, design,...
  • 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...
  •  
    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 is a Transfer Pricing Senior Manager Economist at Meijburg & Co in Amsterdam and has over 8 years of relevant experience. His specialization addresses the economic aspects...