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WebinarWebinar: Managing Substance in Transfer Pricing

This approximately 1.5-hour interactive webinar is the second of two webinars that will be dedicated to substance, the increasingly important notion of international taxation and transfer pricing (TP).
EUR 85 / USD 99 (VAT excl.)
Client offer:
Client offer: 20% discount for IBFD Membership clients and 10% discount for Global Tax Explorer (Plus) clients.
Bulk discount: a 20% discount will be applied to registrations received for 5 people or more made in one order. 
Please note: Registrations to the live webinar will be closed at noon (12.00 CET) one day prior to broadcast and/or when the maximum number of registrations has been reached. Webinars can only be purchased by credit card.
Webinar: Managing Substance in Transfer Pricing

Overview and learning objectives

The webinar will help participants identify and interpret substance requirements and bring forward relevant court cases and guidelines from tax administrations. The webinar will also explore how companies can manage and comply in practice with substance requirements in relation to transfer pricing. The OECD Transfer Pricing Guidelines, the impact of Actions 5 and 8-10 of the OECD BEPS package and domestic substance requirements will equally be covered. This webinar on the topic of substance will complement the first substance-related IBFD webinar, Substance in International Tax Planning, which explains the importance and practical consequences of the notion in the realm of domestic law and tax treaty anti-abuse measures as well as EU law.

Topics to be discussed in this webinar include the relevance of substance, the interpretation and impact of the notion in relation to transfer pricing comparability factors such as functional/risk analysis, R&D and IP, business restructuring, tax-efficient supply chain structures (manufacturing and services) and intra-group financing. Permanent establishment issues (PE risks) and attribution of profits to PE and the relevance of substance in this regard will lightly be touched upon as well.  

After following this webinar, you will be able to:

  • identify substance requirements in domestic TP legislation and international documents
  • interpret and define the scope of the requirements and manage compliance with them
  • apply the guidance laid down by tax administrations, courts and international organizations in the TP field

Field of study


Who should participate

The webinar is suitable for all tax professionals, including accountants, in-house tax personnel (e.g. directors, managers), lawyers and tax advisers who deal with cross-border transactions, structures or cases and wish to understand the risks, challenges and controversies related to TP substance requirements in the post-BEPS world. 

Course level and prerequisites

This is an intermediate-level webinar. Participants taking this course are expected to be aware of the common international tax planning techniques and the practical problems related to them. 

Advance preparation

Participation to this webinar does not require any preparation.

Interactive webinar - "Group Internet Based" (live webinar only)

To safeguard the interactive nature of the webinar, a limited number of participants will be accepted. Early registration is therefore recommended. During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions or to complete short tests. Participants will also have access to the on-demand version for a further 12 months from the live date.
Date of live broadcast: 22 March 2018.

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation or assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant CPE credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.

The International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors.  State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit.  Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBA possible CPE credits - 1.5 (only applicable to live webinar​).

Webinar registration details

If you have any questions regarding following the webinar, technical requirements, and payments and cancellations, please consult our FAQ.

  • Setting the scene
  • Tax-efficient supply/value chain structures
  • R&D activities and exploitation of IP
  • PE risks and attribution of profits to PE
  • Intra-group financing and substance 
  • Connection with TP documentation
    Tamás Kulcsár is a Manager at IBFD’s Tax Services team, as well as contracted expert of the IMF, with over ten years of experience in international tax, transfer pricing and VAT...
  • 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...
    Jeroen Kuppens is the Director of KPMG Meijburg & Co’s Transfer Pricing & Value Chain Management (VCM) Team in Amstelveen. He specializes in TESCM and Transfer Pricing design and...