Course brochure

Course Description and Business Simulation Approach

The course participants will receive one comprehensive case study that will be dealt with during the whole period of the course – 4,5 days – from every perspective of transfer pricing, for example, financial transactions, business restructurings, allocation of profits from intangibles assets, etc.

The transfer pricing practice dictates the demand for tax experts being able to understand the impact of specific transfer pricing policies on the overall strategic transfer pricing policy of a multinational group and event broader – on all the important tax positions of the enterprise, for example, from a tax treaty or EU law tax perspectives.

Covered Topics

The course participants will be dealing with a comprehensive case study to experience how one issue always triggers the next transfer pricing issue, which build together a single transfer pricing strategy.

The case study is designed on the real case and therefore is as close as possible to the realistic scenarios rather than dry theory.

A representative from the tax administration and from a multinational enterprise will take part in the business simulation game.

The topics to be covered during the course:

• The arm’s length principle
• Transfer pricing methods
• Comparability analysis
• Risk allocation and risk adjusted pricing
• Transfer pricing aspects of transaction involving intangibles
• Transfer pricing aspects of intra-group services
• Transfer pricing aspects of business restructurings
• Transfer pricing aspects of financial transactions

You can expect thought-provoking discussions about transfer pricing challenges, defending different positions and making decisions based on critical assumptions, complex interactions and group engagement.

Participants should realize that this course is very intensive and little free time is available, even in the evenings, where participants are requested to prepare homework for the next day.

Course Details

How to apply

Fill in the registration form on https://www.aanmelder.nl/tpcourse/subscribe

Dates 

11 – 15 September 2023

• Monday – Thursday (11-14 September), from 9:00 till16:30, including a 1,5 hours lunch break and two additional 30 min breaks.
• Friday (15 September), from 9:00 till 12:30, including a 30 min break.

Who will benefit

• Early-Career Transfer Pricing Professionals
• Tax professionals who would like to learn transfer pricing
• In-house tax specialists responsible for the design of group tax policies
• Specialists from the Tax authorities responsible for group tax audits
• Academics in the transfer pricing field

Degree you will receive 

• ACTL certificate of attendance (50% minimum class attendance). The course qualifies for 28 PE hours for the NOB Permanente Educatie. 
• But most importantly – highly-valuable knowledge and experience.
  • You will develop a fundamental understanding of transfer pricing, rationale, requirements and policies
  • You will take a helicopter view on the links between transfer pricing and other areas of international taxation
  • You will prepare yourself for commercial and strategic thinking in
    international tax
  • You will immerse yourself into a game environment to stimulate critical thinking and taking a sound stand in every problem that does not have a high degree of legal certainty

Price

€ 3.400,-
€ 2.900,- (early bird discount)

Deadline

Early bird admission: 28 July 2023
Final admission: 28 August 2023

Lecturers

Rutger Hafkenscheid

Rutger Hafkenscheid is a Partner at Huygens Quantitative Consulting (Amsterdam). Rutger serves a wide range of clients, domestic and international, in real estate, private equity and other industries. He specialises in the quantification of risks and rewards in all aspects of corporate taxation and transfer pricing, from business restructurings to financial transactions, including loan financing, derivatives, and captive insurance. Rutger developed a methodology for the valuation of uncertain tax claims in litigation.

After having served a few years as a counsel to one of the political parties in Dutch Parliament, he started his career as a tax advisor with one of (then) Big Eight accounting firms. In 1995, he continued his career with Arthur Andersen, where he was made partner in 1998. Between 2002 and 2009, Rutger was a tax partner with Deloitte in Amsterdam, where he was Community Head from 2006 to 2008. From 2013 onwards, he worked as a counsel in the transfer pricing and economics practice of Loyens & Loeff.

Dr. Svitlana Buriak

Svitlana Buriak is an Ass. Professor at the University of Amsterdam and Director of the Amsterdam Center for Transfer Pricing and Income Allocation. She successfully defended her doctoral dissertation in Business Tax Law at the Vienna University of Economics and Business.

She is also a tax adviser at Loyens & Loeff (Amsterdam). Svitlana specialises in international and European tax law, and transfer pricing. Svitlana advises clients on matters such as IP structures, business restructurings, intra-group financial transactions, implications of OECD Pillar II, transfer pricing and state aid, etc.

Steffanie van der Kroon

Steffanie van der Kroon is a tax adviser at Loyens & Loeff (Amsterdam). She advises multinationals on international tax law, with a focus on transfer pricing. Steffanie specialises in Dutch corporate tax issues in international structuring and restructuring.

She is further involved in a broad range of transfer pricing related issues, such as the implementation and evaluation of transfer pricing systems, obtaining advance pricing agreements, assisting with business restructurings and value chain analyses as well as the preparation of the required transfer pricing documentation.

Representative of the Tax Authority

Aarnout Hamelink

Aarnout Hamelink was educated as an accountant and tax expert and has broad and deep experience within the Tax Administration in corporate income tax, with a focus on transfer pricing.

Positions Aarnout has held include income tax and corporate income tax specialist in the SME segment, corporate income tax specialist and client coordinator with focus area large enterprises, secretary of the Transfer Pricing Coordination Group, content manager of the APA team, negotiator on behalf of the Tax Administration in many Multilateral Agreement Procedures and Bilateral Advance Pricing Agreements and Technical Advisor Corporate Income Tax of a unit in which the construction, trade and industry sectors are represented in the large enterprises segment. Aarnout takes noticeable pleasure in providing
professional guidance to individuals and groups and has extensive experience in this too within and outside the Tax Administration.

Representative of an MNE

Önder Albayrak

Önder Albayrak is the Head of Transfer Pricing within the Tax Strategy & Operations team of Sanofi, a global biopharmaceutical company providing healthcare solutions in more than 170 countries. Following his career at a Big4 firm, he moved in 2006 to industry to work at Genzyme a NASDAQ-listed biotechnology company which gotacquired in 2011 by a Sanofi where he  pursued his career in various regional and global corporate tax and transfer pricing roles. During his twenty+ years of experience in international taxation, he advised and supported corporate, regional and local management, operations, finance and legal teams on international corporate taxation and transfer pricing matters such as intangible assets planning, supply chain and transfer pricing structuring, business expansions and restructurings, post-merger integrations, tax and transfer pricing controversy, negotiations with tax administrations and tax policy matters.