Transfer Pricing Beyond 2025: Adapting to New Challenges and Opportunities

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The global transfer pricing (TP) environment is continuously undergoing rapid transformation, requiring businesses and tax authorities alike to rethink their TP policies and strategy. TP practitioners must navigate shifting business models, the impact of geopolitical conflicts, increasing regulatory scrutiny and the integration of sustainability into tax frameworks – all while managing heightened transparency and compliance demands. Tax technology is revolutionizing how companies manage TP compliance, risk and reporting, while also equipping tax authorities with enhanced audit capabilities and greater access to cross-border data. As jurisdictions intensify their oversight, businesses must optimize their TP policies to align with evolving regulatory expectations, address supply chain disruptions and incorporate environmental, social and governance (ESG) considerations.
Date15 - 17 October 2025
VenueNear IBFD headquarters, Amsterdam
LocationAmsterdam, Netherlands
Early bird discountEarly Bird 10% until 15 September 2025

This comprehensive three-day masterclass delivers cutting-edge insights and practical tools to help participants – whether in-house TP professionals, advisors or tax authorities – effectively adapt to these changes. Expert-led workshops and case studies will explore key areas such as business model transformation, intra-group financing, TP risk management and the intersection of TP with customs. Participants will also gain strategies for managing audits, disputes and compliance in an increasingly complex global tax environment. 

 

Topics Covered

  • Transfer pricing adjustments and Pillar Two
  • Amount B
  • TP and global mobility
  • ESG and transfer pricing
  • TP and global mobility and working from home
  • TP and intangibles
  • TP and intra-group financing
  • TP controversy
  • TP risk management
  • TP and indirect taxes  

Learning Objectives

After this masterclass, the participants will be able to:

  • know the latest developments with respect to Amount B
  • understand the essentials on TP adjustments and Pillar Two
  • understand the TP issues related to ESG
  • know the best practices related to TP and intra-group financing transactions
  • understand the TP challenges and best practices with respect to TP and global mobility
  • understand the TP issues related to IP
  • be able to interpret landmark and recent TP case law
  • be able to identify the customs and VAT consequences related to TP adjustments and vice versa 

Instructors 

Anuschka Bakker

IBFD, the Netherlands

Sharvari Kale

IBFD, the Netherlands

 

Other instructors to be confirmed

Field of study

Taxes

Who should attend

This course is suitable for transfer pricing professionals including in-house TP managers, advisers, lawyers, accountants, economists and finance teams, as well as government officials and tax officers. 

 

Course Level and Prerequisites

This is an intermediate-level course. Participants taking this course will be expected to have a good understanding of transfer pricing. Those who do not meet these requirements are recommended to follow IBFD's online course Fundamentals of Transfer Pricing before they enter this course.  

 

Continuing Professional Education (CPE)

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: www.nasbaregistry.org. Recommended NASBA CPE credits for this course are: 18

Please consult the FAQ for more information. Regarding administrative policies such as complaints, cancellations and refunds, please refer to our Terms and Conditions or contact info@ibfd.org.

Venue

At IBFD headquarters, Amsterdam, Netherlands (or near the office)

Disclaimer

  • IBFD reserves the right to cancel this Masterclass up to 1 month before the commencement date.
  • The programme and line-up of speakers are subject to change.
  • In the unfortunate event of the masterclass being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the masterclass registration fee thereafter. In light of this, participants are kindly advised to make refundable travel and accommodation arrangements. Participants act at their own risk when booking non-refundable travel and accommodation arrangements. IBFD is not responsible for any loss incurred by participants who book non-refundable travel and accommodation arrangements.
  • All bookings related to travel and accommodation, as well as local transportation, visas, vaccinations and travel insurance are at the participant’s own cost.

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