Transfer Pricing Controversy

Setting the scene: Transfer Pricing controversy lifecycle

• Different phases of the TP controversy life cycle
• Roadmap to building a robust TP compliance strategy
• TP implications of the COVID-19 pandemic

Compliance around the globe: Practical aspects

• Key compliance challenges for MNEs and tax authorities
• Roadmap to build a robust TP compliance strategy/defence files
• Court case discussion and lessons learnt
• Automation of TP compliance

Transfer Pricing risk assessment

• Main challenges when undertaking an effective TP risk assessment 
  – tax authority perspective
• Strategy to actively manage TP risks – MNE perspective
• Expert interview on a practical guide to detect TP risks

How to survive a transfer pricing audit?

• Tools to survive a TP audit –do’s and don’ts during TP audit, how to 
  prepare for an audit, and how to train the organization for an audit
• Current controversies and trends including common themes in tax 
  authority approaches in TP audits
• Relevance of joints audits and ICAP

Transfer pricing controversy management: Dispute prevention and resolution

• TP controversy management roadmap including practical tools, 
  strategies and practices
• Effective organization of internal procedures and dispute 
  resolution functions
• Interview setting on the impact of Pillar One on the global 
  TP controversy landscape

Transfer Pricing controversy: Stakeholders and effective negotiation

• Importance of negotiation and storytelling skills
• Principles of negotiation
• Strategies for effective negotiation during transfer pricing disputes: 
  competent authority perspective

Regional and sectoral trends

• Main sources of disputes
• Specific challenges in developing countries
• Addressing TP controversies through tax risk management and control

After following the online course, a tax professional will:

• Identify the different phases of a transfer pricing controversy cycle
• Define the roadmap to building a robust transfer pricing compliance strategy
• Determine the transfer pricing risk assessment strategy from both a taxpayer and tax authority perspective
• Apply the tools to survive a transfer pricing audit
• Identify the current controversies and trends
• Assess the transfer pricing controversy management roadmap
• Define the principles of negotiation and strategies for effective negotiation during transfer pricing disputes

• Adriaan Bijleveld, KPMG, The Netherlands
• Anuschka Bakker, IBFD, The Netherlands
• Eduard Sporken, KPMG, The Netherlands
• Eric Vroemen, PwC, The Netherlands
• Geoff Morris, Independent, The Netherlands
• Joris Nijhuis, Taxtimbre, The Netherlands
• Marek Firlej, PwC, Poland
• Mariusz Kazuch, PwC, Poland
• Marta Kazimierczak, Van Moof, The Netherlands
• Monica Erasmus-Koen, Taxtimbre, The Netherlands
• Sharvari Kale, 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: 12 hours 58 min

All mandatory course activities can be completed within the access period by dedicating approx. 1 hour 30 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: 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

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.