Principles of International Transfer Pricing
50+ hours of video, 24 hours of classes & source documentation for ADIT CIOT Mod 3.03 exam Our next live classes start 22 Feburary 2025
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The aim of this course is two fold:
- It provides students with an overview of international transfer pricing, over what would be a full 5 day course if taught in person;
- It helps prepare students doing the UK Chartered Institute of Taxation (CIOT) doing the Advanced Diploma in International Taxation (ADIT) for Module 3.03 - Transfer pricing, by discussing all topics required in their 2025 syllabus.
Students are taken through:
- basic concepts in transfer pricing such as the arm's length principle, functional analysis, comparability and transfer pricing methods;
- the OECD Transfer Pricing Guidelines and the UN Practical Manual on Transfer Pricing;
- specific transactions, permanent establishments, compliance issues and dispute resolution; and
- recent developments in case law, treaties and at intergovernmental fora such as the UN, the OECD and the EU.
- You get 50+ hours of video lectures available as soon as you sign up. Each lecture typically lasts 12 - 20 minutes.
- We have 9 interactive online classes Sa. 2 PM - 4 PM Amsterdam time from 22 February 2025. Classes will be recorded for review and for those who cannot attend.
- You get 3 interactive online exam preparation classes from end of May in which we discuss old papers and best exam strategies.
- You get continuous support. We respond within 24 hours to questions and comments you may have and are always ready to explain any material you may find difficult to understand.
- You get quizzes after each pre-recorded lecture section to test your knowledge, together with 2 interim online multiple choice test, a final multiple choice test, and an essay type exam to monitor your progress and give you feedback on your writing style for the ADIT exams.
- You have access to all videos and classes for 2 years since your signup.
- The course is updated and new lectures are added on a continuous basis to ensure that students have up to date information when going for the exams.
Note for our students from outside the EU: if you experience any difficulties in getting your credit card payment accepted, please let us know at [email protected] and we will send you a payment link via Stripe, as soon as possible, usually within 2 hours.
Your Instructor
My passions are tax and teaching. I love reading and understanding treaties, laws and directives; seeing how they are shaped in case law and then explaining all that in clear, simple terms with references to real life practical examples. I enjoy interacting with people, raising questions and getting them to connect the dots so that ultimately they feel comfortable with the material and their skills.
I teach transfer pricing, international corporate taxation, and Pillar 2 in a variety of formats: online automated, online face to face, and in person. My typical audiences are: governments, universities, tax professionals with continued education requirements, professional service providers and post graduate students following the Chartered Institute of Taxation’s exams for an Advanced Diploma in International Taxation (#CIOT and #ADIT).
In my teaching I bring to the table my 25+ years experience in international tax and transfer pricing from working in Amsterdam, London, New York and Copenhagen; working for large law firms, accounting firms, the Danish government and various multinationals in various industries. I also published books and numerous articles on taxation, and am currently the editor of PE Plus, an international database on the taxation of permanent establishments.
Please have look at:
Bettertax.info - our business website;
Our Youtube channel where we discuss various tax topics; and
LinkedIn - for my personal profile. Send me an invite so we can stay in touch :-).
You can reach me at: [email protected] or +45-6120 2911.
Course Curriculum
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StartI.A1 Introduction to sources of transfer pricing (10:14)
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StartI.A2 TP Sources - Treaties art. 9 (16:25)
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StartI.A3 TP Sources - Treaties Articles 11 and 12 (16:24)
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StartI.B TP Sources - 2022 OECD Transfer Pricing Guidelines (31:43)
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PreviewI.C TP Sources - OECD BEPS Actions 8-10 and 13 (15:07)
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StartI.D&E TP Sources - the UN Practical manual and Case law (9:24)
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StartI.F TP Sources - EU Joint Transfer Pricing Forum (11:30)