Recent developments in transfer pricing

Multinational groups operating centralized business models are facing new challenges in the post-BEPS, post-pandemic era to align their global value chains and transfer pricing arrangements. At the same time, pressures to be closer to the sourcing, markets and talent are pushing multinational groups towards a less centralized, multi-hub model. Government restrictions and sanctions caused by geopolitical instability add to an already complex landscape. What do multinational groups need to do to maintain or update their transfer pricing arrangements in this environment?

Topics Covered

Block 1: Transfer pricing challenges

Post BEPS, post-pandemic challenges in the application of OECD Transfer Pricing Guidelines to centralized business models, which include:

  • Relationships between substance and remuneration models under OECD Guidelines
  • Transfer pricing impact of COVID-19 pandemic and government sanctions
  • PE and transfer pricing arrangements
  • Near-shoring and multi-hub arrangements

Block 2: Current issues in transfer pricing

Current issues and risks in transfer pricing arrangements which include:

  • Supply chain reorganization
  • Post-pandemic working arrangements
  • Centralized services e.g., sourcing and procurement
  • Distribution and “Amount B”
  • Transparency initiatives e.g., DAC 6, public CbC reports and transfer pricing 

Block 3: Case and Examples

  • Identify and assess the impact of recent developments on intra-group transfer pricing arrangements of multinational enterprises

Learning Objectives

After this webinar, the participants will be able to: 

  • Identify the challenges in the application of the OECD Transfer Pricing Guidelines to centralized business models in the post-BEPS, post-pandemic era;
  • Assess the implications of recent changes driven by BEPS and COVID developments and those affecting the business models and the associated transfer pricing arrangements of multinational groups; 
  • Compare the options that could be taken in response to these recent changes and to revising the associated transfer pricing arrangements accordingly.


  • Sandra Estevez
  • Monique van Herksen

Field of study


Who should participate

This webinar would benefit:

  • In-house tax professionals and advisers looking to understand the impact of recent events on the transfer pricing arrangements of multinational groups that operate a centralized business model; 
  • Legal professionals assessing the risks of transfer pricing arrangements following BEPS and COVID developments and how best to mitigate such risks; 
  • Government officials engaging in monitoring and controlling the compliance activities of multinational groups, as well as those involved in auditing their transfer pricing arrangements. 

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

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. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 01 June 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the 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 continuing professional education (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. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE 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 CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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