Recent developments in transfer pricing
Multinational groups operating centralized business models are encountering new challenges in the post-BEPS, post-pandemic era to align their global value chains and transfer pricing arrangements. At the same time, pressures to be closer to sourcing, markets, and talent are driving multinational groups towards a less centralized, multi-hub model. Government restrictions and sanctions resulting from geopolitical instability contribute to an already complex landscape.
What steps do multinational groups need to take to maintain or revise their transfer pricing arrangements in this environment?
Upon completing this webinar, you will be able to:
- Identify the challenges in applying the OECD Transfer Pricing Guidelines to centralized business models in the post-BEPS, post-pandemic era
- Evaluate the implications of recent changes driven by BEPS and COVID developments, particularly those affecting business models and the related transfer pricing arrangements of multinational groups
- Propose the options available in response to these recent changes and adjust the related transfer pricing arrangements accordingly.
Block 1: Transfer pricing challenges
- Post BEPS, post-pandemic challenges in the application of OECD Transfer Pricing Guidelines to centralized business models, including:
- Relationships between substance and remuneration models under OECD Guidelines
- Transfer pricing impact of COVID-19 pandemic and government sanctions
- PE and transfer pricing arrangements
- Near-shoring and multi-hub arrangements
Block 2: Current issues in transfer pricing
- Current issues and risks in transfer pricing arrangements which include:
- Supply chain reorganization
- Post-pandemic working arrangements
- Centralized services e.g., sourcing and procurement
- Distribution and “Amount B”
- Transparency initiatives e.g., DAC 6, public CbC reports and transfer pricing
Block 3: Case and Examples
- Identify and assess the impact of recent developments on intra-group transfer pricing arrangements of multinational enterprises
Sandra Estevez - Head Global Tax, Talend
Monique van Herksen – Tax Partner, Simmons & Simmons
This webinar is a must if you are:
- An in-house tax professional or adviser looking to understand the impact of recent events on the transfer pricing arrangements of multinational groups that operate a centralized business model
- A legal professional assessing the risks of transfer pricing arrangements following BEPS and COVID developments and how best to mitigate such risks
- A government official engaging in monitoring and controlling the compliance activities of multinational groups, as well as those involved in auditing their transfer pricing arrangements.
This webinar is for tax knowledge of an intermediate level. You are expected to have at least 3 to 5 years of experience in international tax, and be familiar with key concepts in international tax law.
This is an on-demand webinar. Our on-demand webinars are intended for you to self-study only. Unlike live webinars, you will not be able to interact and the instructor will not be able to assist you. Once purchased, you will have access to it for a period of 12 months.
If you have any questions regarding following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.
Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. NASBA CPE credit – 1 (only applicable to live webinar).
- Field of study: Taxes
- Recording date: 1 June 2023
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.


