Transfer Pricing and Intangibles

Importance of Intangible Property (IP) in Global Value Chains

• Importance of intangibles for MNEs and their global value chains
• Importance of intangibles for tax authorities
• Roadmap to determine the key drivers of value for intangibles
• Six-step analytical framework for analysing transactions involving intangibles

Identifying intangible property

• Different categories of intangibles and different perspectives (tax, legal, 
  accounting and finance)
• Guidance for identifying intangibles relevant for transfer pricing purposes
• Discussion of case study with practical example

Attribution of intangible related returns

• Practical guide to apply the DEMPE concept to determine allocation of
  intangible-related returns
• Different pricing methods and valuation techniques
• Practical questions related to transactions involving intangibles and the 
  impact of the global tax reform under the two-pillar solution

Hard-to-value intangibles

• Defining hard-to-value intangibles (HTVIs), typical features of HTVIs, 
  OECD’s recommended approach, and HTVI pricing issues
• Jurisdiction–specific guidance on HTVIs and practical application of 
  OECD HTVI approach along with a numerical example

Regional and Sectoral challenges in analysing intangibles

• Regional trends in relation to IP structures
• Life sciences sector challenges and trends with respect to intangibles
• Digital sector challenges with respect to intangibles
• Media and entertainment sector challenges and trends with respect 
  to intangibles

IP planning/ structuring

• Different IP structures: traditional vs digital
• Emerging challenges and practical considerations in relation to intangibles
• Migration of intangibles and relevant case law decisions

Skills practiced and developed during the course include:

• Identifying the key drivers of value creation with respect to intangibles
• Defining the 6-step analytical framework to analyze transactions involving intangibles
• Defining the different categories of intangibles and how to identify intangibles for transfer pricing purposes
• Apply the DEMPE concept to determine allocation of intangible-related returns
• Identifying the practical aspects of dealing with transactions involving intangibles
• Apply the OECD hard-to-value intangibles guidance and country specific guidance
• Identifying the regional and sectoral trends in respect of intangibles

This course will benefit tax professionals working in multinational groups, tax and legal advisory firms and governments, including:

• Tax lawyers from law firms and/or accounting firms
• Tax/transfer pricing staff from law firms and/or accounting firms
• Finance managers/controllers from MNEs
• Tax inspectors from tax administrations, government officials, academics 

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.

• Ágata Uceda, KPMG & Co | The Netherlands
• Anuschka Bakker, IBFD | The Netherlands
• Anca Aron, IBFD | The Netherlands
• Giammarco Cottani, Netflix | The Netherlands
• Froukje Frerichs, Deloitte | The Netherlands
• Kerry Lambrou, Deloitte | The Netherlands
• David van Peursen, Deloitte | The Netherlands
• Lucas de Heer, Netflix | The Netherlands
• Maaike van Velzen, Deloitte | The Netherlands
• Isabel Verlinden, PwC | Belgium  
• Stefaan de Baets, PwC | Belgium
• Onder Albayrak, Sanofi | The Netherlands
• Sjoerd Haringman, Deloitte | The Netherlands

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: 8 hours 41 min

All mandatory course activities can be completed within the access period by dedicating minimum 1 hour 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 for this course.

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. Issues 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: 11

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 reviewed: January 2025

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.