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WebinarWebinar: Risks and Opportunities in Intra-Group Finance

The OECD has recently issued a discussion draft on the transfer pricing aspects of intra-group finance. This new project gives a good opportunity to look at the challenges and risks MNEs face in the transfer pricing of financial transactions and to discuss with the expert panel members the different ways MNEs can mitigate and manage these challenges and risks.
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. 

Important to note: If you register for a live webinar, your access will remain active for 12 months after the broadcast (in case you are unable to follow it live). Registrations to the live webinar will be closed in the morning, one day prior to broadcast.
Webinar: Risks and Opportunities in Intra-Group Finance

Overview and learning objectives

Topics to be discussed in this webinar include the importance of transfer pricing (TP) considerations for intra-group financing activities, the practical implications of the new 2017 OECD Transfer Pricing Guidelines for financing as well as the new OECD discussion draft on financial transactions. Through practical examples, the instructors will elaborately explain the actual TP exercise on this matter.

After following this webinar, participants will be able to:

  • appreciate the relevance of the new OECD project on intra-group finance
  • interpret the background and the context of the discussion, namely the importance of TP considerations in the realm of financing
  • identify the key challenges MNEs face in setting the arm’s length price for intra-group financing
  • build an analytical framework for approaching and controlling the risks MNEs face in the TP of financial transactions

Field of study


Who should participate?

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

Course level and prerequisites

This is an intermediate-level webinar. Participants taking this webinar are expected to be aware of the common issues of transfer pricing and the practical problems related to them.

Advance preparation

Participation in 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 complete short tests. Participants who follow the live broadcast will also have access to the on-demand version for a further 12 months from the live date.
Date of live broadcast: 27 November 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 from the date of registration and/or live broadcast.

Continuing Professional Education

Many accrediting organizations will grant CPE credit(s) for an IBFD audiovisual 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, payments or cancellations, please consult our FAQ.

  • Setting the scene
  • Recent developments in TP at the level of OECD and their relevance for intra-group finance
  • Introduction to the new OECD discussion draft
  • The current challenges for MNEs surrounding TP of intra-group finance as well as the TP exercise concerning:
    • treasury functions
    • intra-group loans
    • cash pooling
    • financial guarantees
  • Key TP challenges for MNEs
    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...
    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...
  • Rachit Agarwal
    Rachit Agarwal is a Transfer Pricing Director with DLA Piper's Transfer Pricing Team in London, which was awarded the International Tax Review UK and Netherlands Transfer Pricing Firm...