New York Professional Events List

Transfer Pricing

Jun 20, 2019 - 09:00 AM
IMF Academy
It's a distance learning course

ZIP: ----
Phone: +31 (0)40 246 02 20

Ticket Price: €2.480,- (VAT excl.)

How to deal with international Transfer Pricing risk?


The global Transfer Pricing landscape is fraught with uncertainty and complexity. Transfer Pricing has drawn the attention of tax authorities and taxpayers worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing Guidelines by both tax authorities and multinationals have created ground for many disputes.


A significant Transfer Pricing issue facing multinational enterprises (MNEs) is Base Erosion and Profit Shifting (BEPS). On October 5, 2015, the OECD released the final BEPS reports to address perceived gaps in the international tax and transfer pricing rules in order to eliminate so-called ‘double non-taxation’ as well as no or low taxation, associated with practices that are perceived to segregate taxable income from the activities that generate them. The existing OECD Transfer Pricing Guidelines (TPG) are changing and policies that previously were compliant may need to be reviewed and in some cases, changes to the pricing made. It is now time for multinational enterprises to determine what practical implications they face and how they can best operate within this radically changed regulatory environment.


Major Transfer Pricing issues and concerns

This Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property, Customs and, of course, the implications of BEPS for Transfer Pricing.


Target group of this Transfer Pricing course

This toplevel distance learning course on Transfer Pricing was designed to provide in-depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing.

The course is relevant for Transfer Pricing Managers, (inter)national Tax Managers and firms, Finance Directors, Treasurers, Senior Executives with an interest in the latest developments in Transfer Pricing and Lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing environment.

Note! Salary surveys among accountants, lawyers and economists reveil that practitioners with advanced Transfer Pricing knowlegde often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise.


Course materials

The course consists of 11 lessons, each of which will require about 4 hours of self-study. All course participants receive a Certificate of Participation.


Transfer Pricing CPE credits

It should be noted that this Transfer Pricing course may qualify for CPE credits pursuant to the rules of a number of professional associations. Participants are encouraged to check with their professional association to determine eligibility in this respect.


Why a distance learning course on Transfer Pricing?

IMF Academy uses distance learning as an alternative and a complement to traditional training methods in order to make course materials accessible to large audiences worldwide. The greatest advantage is to be not confined by such constraints as geographical location and time. Thus, any client, anywhere in the world, can benefit from IMF Academy's distance learning programs at a time and place convenient to him or her. At the end of every distance learning course, you receive a certificate, acknowledging completion of the course.

Transfer Pricing Sponsorship Opportunities

Improve and increase your organisations profile and network to key industry professionals: your potential clients. Position yourself in front of your target audience to showcase your services by means of sponsoring our courses and trainings. To learn more about sponsorship opportunities, please contact us for an interesting and tailored offer.


Transfer Pricing: Introduction

  • The context of the Transfer Pricing Process
  • Basic Principles and Terminology, Methodologies

Documentation Requirements in the regulatory context of Transfer Pricing

  • The OECD Transfer Pricing Guidelines
  • Factors determining Comparability
  • Introduction to Transfer Pricing Methods

Transfer Pricing Legislation and Guidelines

  • US - the country of origin
  • OECD - setting a global standard
  • Europe
  • Australia
  • Asia
  • Latin America
  • Trends in national, regional and global Documentation Standards

Design and Implementation of a Transfer Pricing Policy

  • The Transfer Pricing Process
  • Designing examples for Goods, Services and Intangibles

Transfer Pricing Documentation: practical aspects

  • Transfer Pricing Documentation three concepts
  • Use of the Master File in practice
  • Use of country-specific Files in practice
  • Best practices of Transfer Pricing Documentation

Transfer Pricing (pre-) Controversy Management

  • Connectivity between 4 boxes
  • Audit procedure
  • Advance Pricing Agreement (APA)
  • Mutual Agreement Procedure (MAP)
  • EU Arbitration Convention
  • Penalties and Interest
  • Pre-Controversy Management Tools
  • Case examples

Transfer Pricing Project and Risk Management

  • Transfer Pricing Project Management
  • Transfer Pricing Documentation and Risk Assessment

Types of inter-company Transactions

  • List and examples of the most common inter-company Transactions
  • List and examples of more complex inter-company Transactions
  • Toolbox for analysis

Transfer Pricing of Intangibles

  • The context of Transfer Pricing of Intangibles
  • Labelling of Intangibles
  • Identification of Intangibles
  • Ownership of Intangibles
  • Valuation of Intangibles
  • Examples

Business Restructuring and Valuation

  • Definition of Business Restructuring
  • Country-specific considerations
  • Analysis of the situation before versus after Business Restructuring
  • Valuation aspects of a Business Restructuring
  • OECD Guidelines Chapter IX
  • TR 2010/D2
  • Case Study

Transfer Pricing and Customs

  • Differences and similarities between the 2 sets of rules
  • The international debate on harmonization of Transfer Pricing and Customs Valuation
  • Price and Profit Adjustments

Speaker Details

Highly acclaimed instructors from Transfer Pricing Associates

Transfer Pricing Associates, part of the TPA Global group, is the leading independent provider of global Transfer Pricing services. TPA has offices and coverage in over 30 countries around the world and has an extensive practical knowledge and experience in a broad range of Transfer Pricing issues. TPA provides high quality Transfer Pricing advice and assistance to multinationals of all sizes, wherever they are located. For more details of the innovative services of TPA, please vist their website The editor of the Transfer Pricing course is

Steef Huibregtse
Steef Huibregtse is the Founding Member of TPA. He is a member of the Business Advisory Group to the OECDs Joint Working Group on Business Restructuring. Steef developed a Global Transfer Pricing Risk Management tool and developed a Global Benchmark Platform and was involved in more than 1.000 regional an global Transfer Pricing studies.

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Event Categories
Keywords: Finance , Financial , access , arts, audience, business , design , development , environment, graphical


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