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UnscheduledTransfer Pricing and Substance Masterclass

This masterclass will address questions such as how “create value” translates into a price or transfer pricing methodology, how to approach a value chain analysis and how to get the information related to CbC reporting out of an organization.


Please note: This course is not currently scheduled. The price, program and instructors are detailed as per the previous course for information purposes only and may be subject to change.
Tax Courses
Amsterdam - The Netherlands
Course code:
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 Substance Masterclass

Overview and learning objectives

The OECD BEPS project focuses on two items: substance and transparency. This is reflected in the reports published by the OECD on, inter alia, services, intangibles, intra-group financing and country-by-country (CbC) reporting. The BEPS reports entail changes for day-to-day business operations. Businesses have already taken action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different countries. The masterclass addresses questions such as how “create value” translates into a price or transfer pricing methodology, how to approach a value chain analysis, how to get the information related to CbC reporting out of an organization and whether your organization is ready to meet the transfer pricing documentation requirements efficiently. Tax disputes are increasing in number. It is therefore essential to be aware of such disputes and to be prepared for resolving them in a methodical and timely manner. That will increase your chances of survival in tax disputes.

This advanced-level, interactive masterclass consists of case studies and sharing best practices. It is designed for participants who already have knowledge of transfer pricing and want to gain more in-depth understanding of the implications of BEPS in their day-to-day practice. Participants will receive a roadmap for the changes that each of the BEPS reports on transfer pricing brings and how these reports are interrelated. 

The objective of the masterclass is to introduce the participants to changes flowing from the OECD BEPS reports. The masterclass is designed to provide an understanding of the finer details pertaining to the practical implementation of the guidelines laid down in the BEPS reports. This will be done by means of case studies and sharing best practices focusing e.g. on specific transactions, such as services, intra-group financing and intangibles. Following a brief introduction to the individual topics, each session is complemented by a case study applying the principles in practice. 

Field of study


Who should attend

The course is suitable for transfer pricing advisers, lawyers, accountants, in-house transfer pricing managers, controllers and finance staff.

Course level and prerequisites

This is an advanced-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. 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: 20.5 (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.

  • Case study: applying arm’s length principle and transfer pricing methods
  • Case study: intangibles
  • Case study: services
  • Case study: intra-group financing
  • Case study: compliance
  • Case study: dispute resolution


  • Clive Jie-A-Joen
    Clive Jie-A-Joen works in the Financial Markets practice group of Simmons & Simmons LLP. His practice focuses on analysing, designing, planning, organizing, documenting and defending the...
    Önder Albayrak is Deputy Head of Global Transfer Pricing & Tax Lead Benelux at Sanofi, a top health care company present in more than 100 countries. He has 17 years of experience in...
  •  Sandra Esteves
    Sandra Esteves is the Director Global Transfer Pricing/Global Enterprise Model (TP/GEM) at SABIC, a leading chemicals company. Before joining SABIC, she worked in the international tax and...
  • Stefan Ubachs
    Stefan Ubachs is a Senior Manager at Quantera Global. He has 15 years of experience in international tax in combination with transfer pricing.   Prior to joining Quantera Global in 2013...
  • Joris Nijhuis is a Senior Manager at Taxtimbre. He focuses on operational transfer pricing, implementation and automation. His activities consist of setting up the right transfer pricing...
  • Hans Geluk is global transfer pricing manager at Danone. He has extensive experience in transfer pricing and has gained a broad knowledge on transfer pricing, advising the corporate, finance...
    Eric Vroemen is a partner in the Dutch Tax & Human Resource Services practice of PwC and has over 20 years of relevant experience. He is specialized in transfer pricing. From 1989 until 1996,...