Transfer Pricing | Executive Program

Kennis van Transfer Pricing is een must voor alle economen en financieel specialsten

Transfer pricing is a complex, but important tax topic. It affects the allocation of profits between entities that are part of the same multinational enterprise group and therefore their taxable profits and the tax revenues of countries. Transfer pricing therefore attracts the attention of tax authorities, the wider public and other stakeholders. Whether you are a CFO, controller, financial director, accountant, tax or legal professional, you are increasingly confronted with transfer pricing regulations and obligations and one should be prepared to respond to the challenge.

Transfer Pricing telefonisch in gesprek met internationale collega's

Why take this Executive Program?

Transfer pricing analyses conducted to determine arm’s length transfer prices are often performed by transfer pricing experts. The pricing of transactions between group entities will 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 and practical tooling to steer the experts and to evaluate the performed transfer pricing analyses

Key Facts & Figures of this Executive Program

Start date
The Executive Program Transfer Pricing will start on April 19th, 2023. The lecture days are on Wednesdays from 15.30 - 20.30 PM. Duration of the program: 5 modules.

Fee
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.

Location
Are you participating offline? Then you will be joining us at a location on or nearby Erasmus University Rotterdam, Campus Woudestein.

Language
Spoken language during the program is English; study materials are also in English.

What about the opportunity to learn about and discuss the latest developments, key tools, issues and nuances of determining arm’s length transfer prices? The 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 chance! 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

19 April 2023: Introduction to transfer pricing

Module 2

10 May 2023: Transfer pricing methods and (intra-group) services

Module 3

24 May 2023: Transfer pricing documentation and dispute resolution

Module 4

31 May 2023: Transfer pricing aspects of financial transactions and (post-acquisition) restructurings of multinational enterprises

Module 5

14 June 2023: Transfer pricing cycle and implementation

The purpose of this module is to address the importance of transfer pricing, the legal framework and the basic elements of transfer pricing. Examples of the covered material include:

  • 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 (practical) examples
  • Transfer pricing control framework

This module will be presented by Clive Jie-A-Joen and the Head of Transfer Pricing of a multinational enterprise.

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 transfer pricing methods exist and what each method’s (dis)advantage are. This is necessary for the control during the analysis process. This module focuses on the following important practices:

  • 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

This module will be presented by Clive Jie-A-Joen and the Head of Tax of a multinational enterprise.

In accordance with local transfer pricing regulations and obligations, taxpayers are often required to prepare certain transfer pricing documentation. This module 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

This module will be presented by a representative of the Dutch Tax authorities.

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. Topics will be discussed trough a range of practical examples such as:

  • Analysing and designing TP policy
  • Setting prices and contracts
  • Transactions and journal entries
  • Monitoring and price adjustments
  • Testing and compliance and controversy defence

This module will be presented by a tax director of a Dutch multinational whereby he 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.

After completion, participants will receive a certificate of participation from Erasmus University Rotterdam.

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.

Some reviews:

‘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

E-mailadres
ijgeerkens@ese.eur.nl
Telefoonnummer
010 – 4081492
Adres
Burgemeester Oudlaan 50 | Van der Goot Building, Kamer M5-19
3062 PA
Rotterdam

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