Transfer Pricing and Business Restructuring

Business models and digital transformation

• Business model transformation and the role of data
• Digital transformation – sector approach bird’s eye view
• Why the use of data matters to transfer pricing
• Case study – practical considerations and impact on business models

Importance of business restructurings – tax perspective

• Expert interview on the importance of business restructurings 
  for tax administrations
• Impact of COVID-19 on business models
• Importance of value chain for tax
• Typical operating models for common business functions such as 
  distribution, manufacturing, procurement, and R&D

Recognition of business restructuring

• Main challenges related to business restructurings
• OECD guidance on business restructurings
• Case study discussion

Arm’s length consideration for restructuring

• Risk allocation and impact on pricing including a step-by-step 
  approach to determine an arm’s length compensation for the 
  transfer of “value” in a restructuring
• Options realistically available (ORA) and financial analysis
• Discussion of model answer to case study: Arm’s length 
  consideration for restructuring

Conversion issues and post restructuring issues

• Post-restructuring transfer pricing issues
• Expert interview on tax accounting considerations
• Case study discussion and recommendations

Selected Issues in global value chain analyses

• OECD and UN guidance on location-specific advantages
• Case law on location savings
• Group synergies and workforce-in-place
• Three-step approach to the measurement and allocation of 
  location-specific advantages and other practicalities

Business restructurings and indirect taxes

• Introduction to literature (VAT and customs)
• Discussion of answers to assignment 1
• Discussion of model answer to case study on VAT consequences of 
  transfers of assets and liabilities and the impact of a restructuring 
  of customs procedures

Skills practiced and developed during the course include:

• Identify the drivers for business model transformation and the role of data
• Define the common types of business restructurings and the related policy framework
• Identify the important considerations in the accurate delineation and non-recognition of business restructurings
• Apply the various concepts such as options realistically available and commercial rational behavior in relation to business restructurings
• Apply the four-step approach for determining an arm’s length compensation for the transfer of “value” in a restructuring
• Identify the tax accounting considerations and reporting issues related to the business restructurings
• Assess the impact of business restructuring from a VAT and customs perspective

• Bo Wingerter, EY, The Netherlands
• Bram Le Bruyn, Deloitte, Belgium
• Brian Mulier, Bird&Bird, The Netherlands
• Britt de Moor, PwC, The Netherlands
• Hans Geluk, Danone, The Netherlands
• Jeroen Kuppens, KPMG, The Netherlands
• Marleen van Buren, PwC, The Netherlands
• Pieter van Lunen, PwC, The Netherlands
• Sharvari Kale, IBFD, The Netherlands
• Zachary Somers, IBFD, The Netherlands

The course is open for all; however, it would be highly beneficial for:

• Tax lawyers from law/and or accounting firms
• Tax/TP managers of law/accounting firms
• Tax/TP managers/directors of MNEs
• Finance manager/controllers/treasury managers of MNEs
• Tax inspectors from tax administrations

This course may also be considered essential for individuals preparing for CIOT ADIT Module 3.03 – Transfer Pricing option, though it is not specifically designed for the ADIT. More information about this qualification can be found on the CIOT ADIT website.

No advance preparation is necessary. All required study material is provided within the online training.

Access to the online course is granted for a period of 2 months, from the date of ordering or the indicated start date.

Mandatory course activities: 10 hours 28 min

All mandatory course activities can be completed within the access period by dedicating approx. 1 hours 15 mins of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course.

We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits.

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 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: www.nasbaregistry.org.

Recommended NASBA CPE credits for this course is: 13

See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or contact us at info@ibfd.org. 

Field of study: Taxes

Delivery format: Online - QAS Self Study

Course Last Review : This course was last reviewed in July 2023

Please note that the content of this online course is subject to change based on updates in industry standards, regulatory requirements, and other developments. We strive to provide the most accurate and current information; however, we recommend verifying any critical details independently.

Group Participation

If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.