Course period: 3 April 2023 - 3 June 2023, 8 lectures

Overview of the course
3 April 2023, 14.00-17.30* and 4 April 2023, 09.00-12.30
Dr. Richard Collier - Introduction, conceptual problems with the ALP, issues with income PE profit attribution
11 April 2023, 14.00-17.30 and 12 April 2023, 09.00-12.30
Prof. Jerome Monsenego - Operation of transfer pricing in practice, the nature of the ALP and relevant practical, technical and conceptual problems
17 April 2023, 14.00-17.30 and 18 April 2023, 09.00-12.30
Ian Dykes - Analysis and critique of the use of the ALP in international tax avoidance and the BEPS response to it
22 May 2023, 14.00-17.30 and 23 May 2023, 09.00-12.30
Dr. Richard Collier - The problems created by the digitalization of the economy, other long-standing problems and the future of the ALP
30 May -2 June: Exam
* Central European Summer Time (CEST)
Course instructors:

Dr. Richard Collier
Richard's work focuses on the rules for the cross-border allocation of income relating to transfer pricing and permanent establishments. He has also worked extensively on financial sector tax issues and topics relating to international tax policy.
Richard has written a book on the Arm’s Length Principle after the OECD's BEPS project and authored or co-authored many article on the income allocation rules, most recently on the future of the ALP and on problems arising with the recently introduced risk framework

Prof. Jerome Monsenego
Jérôme Monsenego is a full professor of international tax law at Stockholm University, and Chairman of IFA Sweden. He has previously worked as an international tax director at PwC.
He obtained his PhD summa cum laude and was awarded an honourable mention by the jury of the IFA Mitchell B. Carroll Prize for his doctoral thesis Taxation of Foreign Business Income within the European Internal Market (IBFD Doctoral Series 2012). He has published articles on various issues of international taxation and two books: Introduction to Transfer Pricing (Kluwer Law International 2015) and Selectivity in State Aid Law and the Methods for the Allocation of the Corporate Tax Base (Kluwer Law International 2018) that was shortlisted for the 2019 IBFD Frans Vanistendael Award.

Ian Dykes
Ian Dykes is a Transfer Pricing Partner at PwC United Kingdom.
Ian has over 25 year's experience of advising UK and foreign businesses and has worked with many large multi-national firms. Ian is nationally and internationally recognised expert in Transfer Pricing and prior to taking on his current role, he ran PwC's Transfer Pricing network in the United Kingdom.
How to apply
You can register for the Advanced Transfer Pricing Spring Course 2023 by sending an email actp-taxlaw@uva.nl
To attend this course, you must meet the entry requirements that include your previous education and English language proficiency. Please check entry requirements below.
If you have any questions about the course, please send an email to: actp-taxlaw@uva.nl
-
Entry requirements
- Your previous education must satisfy the requirements listed below (see ‘Previous education’):
- It is highly valued during the selection process if your previous study programme included courses on tax law, or if you have acquired relevant competencies through work experience in tax law (see ‘Tax law’ below);
- You must have obtained a minimum standard in English language proficiency – see further below;
- You must be willing to participate actively in the classroom; and
- You must have an open mind towards different cultures.
It is possible to apply while finishing a previous degree, in which case acceptance to the programme is conditional on satisfactorily completing the previous degree. We will need these documents before the deadline stated in step 1. Please take into consideration that you have taken the English language proficiency test before you apply to the programme and that the test often get booked up months in advance and the results take more than two weeks to be published.
Previous education
The candidate must satisfy one of the following sets of requirements:
- Have completed a university degree in law that is the equivalent of a master’s degree in the Netherlands. An initial master’s degree from a university that follows the European BA-MA system is equivalent. Degrees from universities that do not follow the European BA-MA system must require a study of at least four years in order to be equivalent; if you are not sure whether your degree is the equivalent of a Dutch master’s degree, please consult us.
- Have completed a university degree in law at bachelor level and be admissible to a traditional legal profession such as advocate, attorney, barrister, judge, notary, solicitor, etc.
- Have completed a Master’s degree from a research university (Dutch: WO) in any discipline, who has obtained at least 30 EC of law courses during university education. An initial master’s degree from a university that follows the European BA-MA system is equivalent to a Dutch master’s degree. Degrees from universities that do not follow the European BA-MA system must require a study of at least four years in order to be equivalent; if you are not sure whether your degree is the equivalent of a Dutch master’s degree, please consult us.
- Have completed an (advanced) Master’s degree from a technical college in a strongly related discipline, namely tax law, fiscal economics, or accountancy. An initial master’s degree from a university that follows the European BA-MA system is equivalent to a Dutch master’s degree. Degrees from universities that do not follow the European BA-MA system must require a study of at least four years in order to be equivalent; if you are not sure whether your degree is the equivalent of a Dutch master’s degree, please consult us.
- Have completed a professional accountancy qualification.
Tax law
It is valuable to have some prior knowledge of tax law, obtained either through university study or work experience. This study or work experience can be in either domestic or international tax law. This helps students entering this programme to have a good understanding of the content of the programme and give them the opportunity to share their knowledge in the field with their fellow students. Applicants that do not have any experience in tax law, either through university study or work experience, will also be considered, provided that they can show a genuine interest in the topic.
English language proficiency
The Amsterdam Law School accepts the following tests and test results:
- TOEFL* (Test of English as a Foreign Language). The minimum TOEFL score required is: 100 iBT, with a minimum of 24 for subscores reading and writing, a minimum of 22 for subscore listening and a minimum of 25 for subscore speaking. Please make sure to mention our institutional code: 9011 when signing up for the TOEFL test so we can verify your scores online.
- IELTS** (International English Language Testing System). The minimum IELTS score required is 7.0, with a minimum of 6.5 for each subscore. Please provide us with a scan of your test report.
- Cambridge English Language Assessment: minimum grade C1 Advanced with a minimum score of 190. Please make sure to ‘share’ your test results with us so we can verify your scores online.
* The TOEFL ITP test (Institutional Testing Program) and the TOEFL iBT special home edition are NOT accepted.
** The IELTS Academic Online, IELTS General Training and IELTS Indicator are NOT accepted.Please note: The Amsterdam Law School only accepts English-language proficiency test results that are no more than two years old at the time of the start of the programme. Chinese applicants will need to submit an IELTS or TOEFL iBT test score and request a Nuffic certificate.
The following students are exempted from the above-mentioned test requirements:
- Students who have received their prior education in one of the following English speaking countries: Australia, Canada (except Quebec), Ireland, New Zealand, the United Kingdom or the United States.
- Students who possess an international or European baccalaureate diploma (with English as the only language of instruction).
- Students who have completed a Bachelor’s or Master’s programme taught entirely in English (note: this does not include exchange, summer school or other non-degree programmes).
- Students who possess a Bachelor’s diploma from a Dutch research university.
Degree certificate
Upon successfully completing the academic programme, you will receive a certificate of attendance issued by the Amsterdam Centre of Tax Law of the University of Amsterdam, which acknowledges your acquired competencies.
Course credits: 3 ECTS
Cost
The tuition fee for registering to the 2023 edition of the spring Advanced Transfer Pricing course is € 1,500. The cost of taking the exam is € 500 (non-obligatory).
The tuition fee is non-refundable.
Location
