Transfer Pricing | Executive Program

Transfer Pricing for Finance en Business Professionals

About the Executive Program

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. Therefore, transfer pricing is attracting ever-growing interest from amongst other policy makers, tax authorities, multinationals, auditors, shareholders, general public and media.

Transfer pricing analyses conducted to determine arm’s length transfer prices are often performed by transfer pricing experts. However, even if experts are being consulted, it is important for finance, legal, and tax professionals to understand the transfer pricing issues. This knowledge is important to steer the experts and to evaluate the performed transfer pricing analyses.

The goal of the Executive Program Transfer Pricing is to offer you the opportunity to learn about and discuss the key tools and issues of determining arm’s length transfer prices. This will enable you to identify and control transfer pricing risks at the right time and to ask the right questions. It will also provide insights into the transfer pricing analyses conducted to determine arm’s length transfer.

Target group

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 a perfect opportunity.

Important information:

Location lecturesNearby Erasmus University Rotterdam, Campus Woudestein
Lecture daysWednesdays (15.30 - 20.30)
Start date

12 October 2022

Duration of the program5 modules

Offline participation: €2.700 or €575 per module
(including parking ticket, food and drinks; exempt from VAT)

Online participation: €2.375 or €475 per module


Content of the program

Module 112 October 20222
Module 219 October 2022
Module 316 November 2022
Module 430 November 2022
Module 57 December 2022

This Executive program consists of the following five modules. Each module takes place on Wednesdays and starts at 15:30 and ends at 20:30.

Module 1: Introduction to transfer pricing

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.

Module 2: Transfer pricing methods and (intra-group) services

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.

Module 3: Transfer pricing documentation and dispute resolution

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.

Module 4: Transfer pricing aspects of financial transactions and (post-acquisition) restructurings of multinational enterprises

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.  

Module 5: Transfer pricing cycle and implementation

This module discusses the technical and practical aspects of the various steps in a transfer pricing cycle (e.g. 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 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.

    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.

    Participants of the Executive Program Transfer Pricing 2019 evaluated the first edition of the program with an eight and program director Clive Jie-A-Joen PhD MBV was assessed with an 8,7. Participants of the Executive Program Transfer Pricing 2020 evaluated the program with an 8,5.

    Participants of EP TP 2020 about the program: “Would definitely recommend it to my contacts interested in this area.” “Excellent organization, good group size and composition. Topics ‘to the point’: completely satisfied!''

    IJfke Geerkens-Verheijden

    Program Coordinator

    010 – 4081492
    Burgemeester Oudlaan 50 | Van der Goot Building, Kamer M5-19
    3062 PA

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