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Amsterdam Centre for Tax Law Amsterdam Centre for Tax Law

Webinar Series on Transfer Pricing Aspects of Intangibles Assets

The ACTP frequently organizes webinars that are attended by alumni students, transfer pricing executives from the industry, public officers, and consultants. The webinars are well received and attended by approximately 75-100 participants. Each webinar is part of a series of three, and each session lasts 1.5 hours, with two speakers and a moderator. In line with ACTP's objectives, the webinars are meant to invoke critical thinking and thus avoid "mainstream" discussions. For example, in the previous webinar series about the Risk Allocation Framework of Chapter I OECD Transfer Pricing Guidelines, Manuel de los Santos (OECD), Richard Collier (Oxford University), Isabelle Verlinden (PwC Belgium), Romero Tavares (Advisory Board, Ministry of Finance of Brazil), Charles Lincoln (US IRS), Emmanuel Llinares (NERA) and Rutger Hafkenscheid (Huygens Quantitative Consulting, ACTP) critically reviewed the framework, and suggested potential improvements and adaptations.
Date
16 November 2023
Time
16:00 -17:00

16 November 2023, 4 pm - Problems with the PE Attribution Rules

  1. Chair: Rezan Okten
  2. Speaker 1: Giammarco Cottani
  3. Speaker 2: Arthur Pleijsier


In this scholarly webinar, we will unravel the complexities and practical challenges inherent in attributing profits to PEs, delving into real-world case studies and recent developments. Our distinguished experts will dissect the nuances of this critical aspect of international tax law, offering fresh perspectives and solutions to navigate the evolving landscape of global taxation.

Registration link:

7 December 2023, 4 pm - Problems with the Relationship between the PE Attribution Rules and the Transfer Pricing Rules

  1. Chair: Svitlana Buriak
  2. Speaker: Richard Collier and Marco Adda


Our forthcoming webinar will consider the relationship between the Article 7 PE attribution rules and the Article 9 transfer pricing rules, focusing in particular on the nature of that interaction in cases of dependent agent PEs where both sets of rules need to be applied simultaneously. The webinar will also address the potential interaction between the AOA and the risk analysis provided by the transfer pricing framework and explore the degree of consistency between the AOA and the fundamental freedoms in the EU framework.

Registration link:

Previous Events

 

 

19 October 2023, 4 pm - Problems with The PE Threshold Test

a     Introduction of the series: Svitlana Buriak and Richard Collier

b    Chair: Rutger Hafkenscheid

c     Speaker: Scott Wilkie

This webinar will provide an in-depth analysis of the multifaceted challenges and nuances inherent to the concept of Permanent Establishment in the realm of international tax treaties. Distinguished experts will discuss the intricacies of PE determination, offering insights into its legal, economic, and practical implications.

Registration link:

This Spring/Summer, the ACTP organises a series of three webinars on transfer pricing aspect of intangibles.

Join the first webinar in the series!

From Cost Contribution Agreements to DEMPE

with Prof. Scott Wilkie and Andrew Hickman, moderated by Rutger Hafkenscheid, already on April 12, 2013, at 2:00 pm CET.

Register
Scott Wilkie

Prof. Scott Wilkie is a Distinguished Professor of Practice at Osgoode Hall Law School, York University and a retired partner of a major Canadian law firm.  Widely published, he teaches and writes broadly about taxation, notably international taxation and tax policy.  He is a former vice-chair of the Permanent Scientific Committee of the International Fiscal Association, served as president of the Canadian branch of the International Fiscal Association, and is a past chair of the Canadian Tax Foundation.

Andrew Hickaman

Andrew Hickman was Head of Transfer Pricing at the OECD between 2014 and 2016 and responsible for the G20 mandated BEPS outputs including the 2017 revisions to the OECD Transfer Pricing Guidelines. Involved in transfer pricing for over thirty years, Andrew was a tax partner with KPMG in London and before that an official with the U.K. tax authority. Andrew now operates as an independent consultant and works on matters that he finds interesting, including disputes, arbitration, research, and has contributed to the work of the UN subcommittee on transfer pricing. He is a research fellow at the Centre for Transfer Pricing and Income Allocation, part of the University of Amsterdam.

Stay tuned: Next webinars in the series

 

When? 11 May, 14:00-15:30 CET

Valuation of intangibles (incl. HTVI) in transfer pricing practice

with Dr. Kerim Keser (Kroll, Germany) and Sebastian Frankenberg (JSB Regatta), moderated by Rezan Okten (ACTP)

Register

When? 14 June, 14:00-15:30 CET

DEMPE and Value Creation: Super profits from IP and Inter-nation equity

with Michael McDonald (EY, US) and Dr. Marta Pankiv (Tricentis, Austria), moderated by Dr. Svitlana Buriak (ACTP)

Register