What about the opportunity to learn about and discuss the key tools and issues of determining arm’s length transfer prices? Executive Program Transfer Pricing will enable you to identify and control transfer pricing risks at the right time. Curious for the latest insights into the transfer pricing analyses conducted to determine arm’s length transfer? This is your program!
Why take this Executive Program?
Transfer pricing analyses conducted to determine arm’s length transfer prices are often performed by transfer pricing experts. Transfer pricing is important for the allocation of profits between entities that are part of the same multinational enterprise group and therefore the taxable profits of these group entities located in various tax jurisdictions. The pricing of transactions between group entities will also affect the commercial accounts as well as the tax returns of these group entities. Moreover, transfer pricing is an important part of the OECD Base Erosion and Profit Shifting Action Plan to tackle tax avoidance by multinational enterprises. By taking the Executive Program Transfer Pricing at the Erasmus University Rotterdam, you gain:
- the opportunity to learn about and discuss the key tools and issues of determining arm’s length transfer prices
- the skills to identify and control transfer pricing risks at the right time (by asking the right questions)
- the latest insights into the transfer pricing analyses conducted to determine arm’s length transfer
- a better understanding of transfer pricing issues for you as a finance/legal/tax professional, even if experts are being consulted
- important tooling to steer the experts and to evaluate the performed transfer pricing analyses
Key Facts & Figures of this Executive Program
The Executive Program Transfer Pricing starts October 12th, 2022. Lecture days are on Wednesdays from 15.30 - 20.30 PM. Duration of the program: 5 modules.
The fee for offline participation is € 2.700,- or € 575,- per module (including parking ticket, food and drinks; exempt from VAT). Interested in participating online? Then the fee is € 2.375,- or € 475,- per module.
Make your choice for online or offline participation on the registration form.
Are you participating offline? Then you will be joining us at a location on or nearby Erasmus University Rotterdam, Campus Woudestein.
Spoken language during the program is English; study materials are also in English.
This Executive program consists of the following five modules. Each module takes place on a Wednesday, starts at 15:30 and ends at 20:30 PM.
Module 1 12 October 2022: Introduction to transfer pricing
Module 2 19 October 2022: Transfer pricing methods and (intra-group) services
Module 3 16 November 2022: Transfer pricing documentation and dispute resolution
Module 4 30 November 2022: Transfer pricing aspects of financial transactions and (post-acquisition) restructurings of multinational enterprises
Module 5 7 December 2022: Transfer pricing cycle and implementation
Examples of the covered material:
- What is transfer pricing and what is the importance and relevance of transfer pricing?
- The arm’s length principle and associated enterprises
- Sources of transfer pricing regulation and legislation
- Transfer pricing aspects and risks related to the main intra-group transactions
- Comparability as the basis of transfer pricing
- Overview and state of the BEPS developments and the impact on day-to-day transfer pricing operations illustrated by examples
- Transfer pricing control framework
You are employed by a multinational company and a transfer price needs to be determined. You have the choice to do this internally or to outsource it. Anyway, you need to know which methods exist and what each method’s (dis)advantage are. This is necessary for the control during the analysis process.
- Choosing and applying the most appropriate transfer pricing method is one of the most important challenges in determining an arm’s length transfer pricing policy
- How should the selected transfer pricing method be applied: benchmarking analysis, comparables, databases, financial analysis and practical issues
- Transfer pricing aspects of (intra-group) services
A representative of the Dutch Tax authorities will discuss several topics including:
- Organization of the Dutch tax authorities on transfer pricing and focus areas
- Transfer pricing documentation: Dutch and international documentation requirements (e.g., Master File and Local File)
- The transfer pricing control framework
- The role of contractual terms
- Mandatory Disclosure
- Transfer pricing audits
- Transfer pricing dispute prevention and resolution: advance pricing arrangement, mutual agreement procedures and European Arbitration Convention
The first part of this module focuses on the transfer pricing aspects of financial transactions, such as determining the arm’s length interest rate for an intra-group loan, the question whether to charge for a financial guarantee or not, and if so, what is an arm’s length guarantee fee. The practical transfer pricing aspects of cash pooling will also be discussed.
The second part of this module deals with the transfer pricing aspects of (post-acquisition) business restructuring of multinational enterprises.
This module discusses the technical and practical aspects of the various steps in a transfer pricing cycle (like analyzing and designing TP policy, setting prices & contracts, transactions & journal entries, monitoring & price adjustments, testing and compliance and controversy defense) through a practical examples. A tax director of a Dutch MNE will elaborate on his experience.
The lecturers in this program are:
Önder Albayrak - Head of Transfer Pricing Strategy & Operations / Head of Tax Benelux at Sanofi
Barend Broen - Transfer Pricing Director at Shell and university lecturer at Erasmus School of Law
Susanne Verloove – Transfer Pricing Associate Partner at EY
Ankitha Dange - Transfer Pricing Manager at EY
Dennis Hovinga – Head of Tax at ASM International
Willem-Jan van Veen – Specialist country by country reporting, exchange and rulings and mandatory disclosure at Dutch Tax Authorities
Clive Jie-A-Joen – Program director, Counsel Transfer Pricing Simmons & Simmons LLP and university lecturer at Erasmus School of Law.
*Changes because of unforeseen circumstances may alter the composition or the dates of the program slightly. These changes will be communicated in a timely manner.
Programme lead & support
The Program Director is Clive Jie-A-Joen PhD MBV. Clive works at Simmons & Simmons LLP, an international law firm. His practice focuses on helping MNEs in designing, implementing and defending their transfer pricing policies, with dispute management always at front of mind. Clive has an economics background (PhD in Economics and Master of Business Valuation) and over two decades of experience in the transfer pricing field. He works together with tax lawyers, finance and legal professionals on transfer pricing issues. Clive graduated Cum Laude and received the Best Student Award for his Master of Business Valuation Study at the Tilburg University.
Clive is also associated with the Erasmus School of Law (as university lecturer) as well as ESAA (which also includes the RC (chartered controller) and RA (chartered accountant) training). In addition, Clive is a board member of the transfer pricing section of the Dutch Association of tax advisors ('NOB'). He regularly lectures and writes articles on transfer pricing. Clive has been quoted as a leader in Transfer Pricing in Legal Media’s Transfer Pricing Advisers Expert Guide. Any practical questions about the program? Contact IJfke Geerkens-Verheijden (Program Coordinator)
Transfer pricing is attracting ever-growing interest from amongst other policy makers, tax authorities, multinationals, auditors, shareholders, general public and media.
Are you a financial director, CFO, Controller, Finance, Legal or Tax Professional, are you dealing with transfer pricing and would you like to increase or update your knowledge of transfer pricing to perform your task even better? This Executive Program offers the perfect opportunity to do so.
Participants of prior editions of the Executive Program Transfer Pricing evaluated the program with an 8,5. Program Director Clive Jie-A-Joen PhD MBV was assessed with an 8,7.
‘Would definitely recommend it to my contacts interested in this area.’
‘Excellent organization, good group size and composition. Topics to the point: completely satisfied!'