Transfer Pricing and Substance Masterclass

20 April 2020, Monday - 22 April 2020, Wednesday

09.00AM - 05.00PM

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Accredited tax professionals enjoy 30% early bird discount (register ≥60 days before course commencement) or 20% discount (before course commencement).
Please refer to organiser’s webpage here.
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Programme Synopsis

The OECD, European Union and UN have been – and are still – implementing guidance related to base erosion and profit shifting (BEPS), and many of these developments affect transfer pricing. Asia-Pacific countries have been – or are still – implementing similar rules in their own tax systems. In addition, the business models of multinational enterprises (MNEs) have been changing, and international organizations and tax authorities in different countries are trying to tax the profits made via these new, data-driven business models. Thus, from a risk management perspective, it is essential for MNEs to be fully aware of the different approaches that are taken by international organizations and various tax authorities with respect to substance, digitalization of the economy, intangibles, intra-group services, intra-group financing, permanent establishments, transfer pricing (TP) documentation and dispute resolution.

The consequences of the aforementioned developments entail changes for day-to-day business operations. Businesses have already taken action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different countries. Monitoring and taking additional actions are needed in the following years. This masterclass addresses questions such as how value creation translates into a price or TP methodology, how to approach a value chain analysis, how to get the information related to country-by-country (CbC) reporting out of an organization and whether your organization is ready to meet the TP documentation requirements efficiently. Tax disputes are increasing in number. It is therefore essential to be aware of such disputes and to be prepared for resolving them in a methodical and timely manner. This will increase your chances of survival in tax disputes.

This advanced-level, interactive masterclass consists of case studies and sharing best practices. It is designed for participants who already have knowledge of TP and want to gain a more in-depth understanding of the implications of changed TP and international tax concepts in their day-to-day practice.

Following a brief introduction to the individual topics, each session is complemented by a case study applying the principles in practice. All the sessions will cover guidance from international organizations and approaches taken by some tax authorities in the Asia-Pacific region.

To safeguard the interactive nature of the course, including group discussions, the number of participants is limited. Early registration is therefore recommended. Participants will be given access to additional reading material and supplementary materials (e.g. legal documentation, case law and related articles/literature).

Programme Outline

  • Workshop Value Chain Analysis
  • Workshop Transfer Pricing and Digitalization
  • Case Study: Intangibles
  • Case Study: Services
  • Case Study: Intra-Group Financing
  • Workshop: The Permanent Establishment: Concept and Profit Allocation in a Digital Age
  • Workshop Compliance
  • Case Study: Dispute Resolution

About the Presenter(s)/ Trainer(s)

Ms Anuschka Bakker
Manager, Transfer Pricing and Specialist Knowledge Group

Anuschka Bakker is the Manager of the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam. In addition, she acts as the Cluster Manager for the transfer pricing courses offered by IBFD International Tax Training. Prior to joining IBFD, she worked for Ernst & Young and PricewaterhouseCoopers. She has many years of experience in international taxation issues, of which the last 12 have been dedicated to transfer pricing. Ms Bakker also lectures and publishes regularly on a wide variety of transfer pricing-related topics. Further, Ms Bakker speaks at transfer pricing conferences around the world.

She holds a master's degree in Tax Law from the University of Groningen, the Netherlands and she holds an MBA from Nyenrode Business University, the Netherlands. Ms Bakker has published over 30 articles and chapters on transfer pricing, tax risk management and tax and environment.

Mr Eric Vroemen
Partner, Dutch Tax & Human Resource Services

Eric Vroemen is a partner in the Dutch Tax & Human Resource Services practice of PwC and has over 20 years of relevant experience. He is specialized in transfer pricing. From 1989 until 1996, prior to joining PwC, Mr Vroemen worked with the Dutch tax authorities as a state auditor and with Deloitte in the Netherlands. In 2001, he was seconded to New York, and from 2003 until 2006 he was located in Chicago as the managing partner of the Dutch Desk. Since 1999, Mr Vroemen has focused on transfer pricing and business restructurings, and has been involved in planning and controversy management for a large number of well-known and complex multinationals. As such, he has obtained an in-depth understanding of business operations in a wide variety of industries. Mr Vroemen is a frequent speaker on transfer pricing and a guest lecturer at the Erasmus University in Rotterdam as well as for the Dutch Order of Tax Advisers.

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