All sessions take place online every three weeks on Wednesday afternoons, from 15:00–17:30 CET.​​

Lecture 1 — 15 April 2026
Transfer Pricing in the Context of Tariffs and Customs
Lara Witte & Mike Cristea
    ∙    What is a customs valuation?
    ∙    TP adjustments and customs value: conflicting objectives
    ∙    Mitigating tariffs using transfer pricing
    ∙    Sales tax/VAT implications of retrospective pricing corrections
    ∙    Seminal customs ruling: customs and TP perspective
    ∙    Case study: Nike case involving $1.5 billion

Lecture 2 — 22 April 2026
Business Restructurings Involving IP Assets
Dr. Svitlana Buriak 
    ∙    Modes of cross-border IP transfers and the delineation and recognition of transactions based on their economically relevant characteristics
    ∙    Transfer of intangibles following M&A transactions and post-acquisition restructuring
    ∙    The role and alignment of DEMPE functions with legal and contractual arrangements
    ∙    Selected case law and the relevance of DEMPE across different business models

Lecture 3 — 13 May 2026
Value Chain Analysis and Business Restructurings in a Volatile Global Economy
Lucia Sahin 
    ∙    Common triggers for business restructurings and operating model responses
    ∙    Analytical framework for identifying transfers of functions, assets and risks
    ∙    Using value chain analysis to document business restructurings and their tax impact

Lecture 4 — 3 June 2026
Global Mobility and Transfer Pricing: the New Frontier
Hans van Egdom 
    ∙    Development of business models, including the consequences for PE
    ∙    Remote work and profit attribution and transfer pricing; OECD and UN interpretations
    ∙    Implications for international taxation and the arm’s-length principle
    ∙    Case study: Global mobility and transfer pricing (“SWEETS”)

Lecture 5 — 24 June 2026
DEMPE in Practice: Substance, Functions and Control
Michael McDonald
    ∙    The DEMPE framework explained: beyond the acronyms
    ∙    Linking functions to returns: DEMPE remuneration vs. DEMPE-based recharacterization
    ∙    Challenges in tech and pharmaceutical industries
    ∙    Case study: IP Transfers and post-transfer intercompany services

Lecture 6 — 15 July 2026
Problems and Implications of the Control of Risk Regime
Richard Collier
    ∙    Legal vs. economic ownership of risk
    ∙    Profit split method: when and how to apply
    ∙    Who makes decisions, and who deserves the return?
    ∙    Case study: Multinational joint development project​​

Lara Witte — Plante Moran

Lara Witte brings more than 20 years of Big Four transfer pricing experience and has led global client service teams on transfer pricing engagements. She has presented at conferences, authored transfer pricing articles, and mentored tax administrations across Africa. She holds a J.D. from the University of Detroit Mercy School of Law and an LL.M. in Taxation with Distinction from Georgetown University Law Center, and completed the Executive Leadership Program at Harvard Business School.

Mike Cristea — MNP
Mike Cristea leads the Tariffs & Trade Advisory group, specializing in customs and trade compliance matters. He is based in Toronto, Ontario. Over more than 25 years, Mike has worked in an advisory capacity, as well as in customs brokerage and in industry. Mike and his team serve clients in varied business sectors including mining and metals, oil and gas, transportation, construction, consumer products, life sciences, and agri-food.

Dr. Svitlana Buriak — Lubbers, Boer & Douma / University of Amsterdam
Dr. Svitlana Buriak lectures on international taxation, focusing on transfer pricing, tax treaties, and EU tax law. She serves as Director of the Amsterdam Centre for Transfer Pricing and Income Allocation, is a visiting lecturer at WU Vienna, and a published author in leading tax journals. Her doctoral thesis received several international academic awards, including the 2025 IBFD Frans Vanistendael Award.

Lucia Sahin — Lucent Advisory BV
Lucia Sahin is an international tax and transfer pricing specialist with over twenty years of experience advising multinationals on complex cross-border matters. She has held senior roles at both Big Law and Big Four firms and is the founder of Lucent Advisory BV. She is also a guest lecturer on transfer pricing at various universities and an active member of IFA and the Dutch Order of Tax Advisors (NOB).

Hans van Egdom — Ministry of Finance, the Netherlands / OECD Working Party 6
Hans van Egdom is a policy advisor at the Ministry of Finance of the Netherlands and co-chair of Working Party 6 of the OECD Committee on Fiscal Affairs. He is the author of a book on transfer pricing in Dutch and is currently working on a book about profit allocation to permanent establishments.

Michael McDonald — University of Virginia
Michael McDonald recently retired from Ernst & Young, where he was a Managing Director in the National Tax Department. He previously served as a financial economist at the U.S. Treasury’s Office of Tax Analysis and co-chaired the transfer pricing work under the OECD BEPS Project (Actions 8–10). He is a lecturer at the University of Virginia School of Law and recipient of the 2017 Bloomberg Tax Transfer Pricing Report Lifetime Achievement Award.

Richard Collier — University of Oxford / University of Amsterdam
Richard Collier is a tax lawyer and accountant specializing in international tax treaties, transfer pricing, and financial instruments. He is an Associate Fellow at the University of Oxford Said Business School and a Research Fellow at the University of Amsterdam Centre for Transfer Pricing. He previously headed the transfer pricing, treaties, and financial transactions team at the OECD and was a tax partner at PwC. He holds an LLM from Cambridge and a PhD from the University of London.

• Cancellation of participation for the whole course (e.g. six lectures)
  In the event that a participant has registered for the full course, cancellation of such registration shall only be permitted up to ten (10) workdays prior to the commencement of the course (13 april 2026). Where cancellation is effected within this period, the participant shall be entitled to a full refund of the registration fee paid. Not attending or cancelling a lecture, when registered, will not lead to a refund for that lecture. 
• Cancellation of registration for selected lectures
  In the event that a participant has registered for one or more selected lectures only, cancellation of the relevant registration shall only be permitted up to and including seven (7) workdays prior to the commencement of the relevant lecture. Where cancellation is effected within this period, the participant shall be entitled to a full refund of the fee paid in respect of the relevant lecture or lectures.
• Late cancellations and non-attendance
  Cancellations received after the applicable deadline referred to above shall not give rise to any right to a refund. Failure to attend the course or any lecture, for whatever reason, shall likewise not entitle the participant to any refund.
• Form of Cancellation
  Any cancellation must be submitted in writing by email to the organiser (m.a.hermans@uva.nl/s.buriak@uva.nl/v.v.a.nohar@uva.nl) or to such contact address as may be indicated in the registration materials. Cancellation must be confirmed to the participant by the organiser, or anyone representing the organiser. 
• Substitution of participants
  A registered participant may designate a substitute participant, provided that the organiser has been notified thereof in writing prior to the commencement of the course or, as the case may be, the relevant lecture. The organiser reserves the right to refuse such substitution where there are reasonable grounds for doing so.
• Changes to the course by the organiser
  The organiser reserves the right to amend the programme, schedule, lecturers, or mode of delivery of the course or any lecture, where reasonably necessary.