A post-BEPS Application
of the Arm’s Length Principle
Online Course
Get geared with the right analytical skills and tools
to effectively address transfer pricing in 2019
Brought to you by
Why TP?
Transfer pricing is one of the most relevant topics in the current international tax environment. Coordinated and unilateral measures undertaken by governments in their efforts to tackle Base Erosion and Profit Shifting ("BEPS") are transforming how companies conduct business across borders.

To help you keep up to date with the developments in this field, we are providing an online, easy-to-access and interactive course experience to get hands on with the application of the post BEPS arm's length principle in practice.
Learning Outcomes
  • Apply one sided transfer pricing methods in appropriate situations: TNMM, Resale Price, Cost Plus
  •  Identify, address and be able to value intangibles in highly integrated value chains
  •  Apply two sided transfer pricing methods in appropriate situations: CUP and Profit Split
  •  Apply the post-BEPS arm’s length principle to financial transactions and management fees
Who is
it for?
This course is relevant for professionals of all levels of experience, who want to build or broaden their knowledge in transfer pricing. This includes:
  • Tax and transfer pricing advisors 
  • In-house tax and finance professionals
  •  Government officials
  •  Academics
100% online
Get practical insights with online sessions covering the latest tax developments.

Accessible 24/7 from anywhere
Attend live or complete lectures at your pace. All you need is an internet-connected device.

Interactive
Get a chance to ask questions and interact with speakers when 
you attend live.

Course Structure
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


Module 1
The Arm's Length Principle and One-Sided TP Methods
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


  Date: March 4, 2019
               14:00 PM CET
  Duration: 1hr 40 min
      Q&A: 30 min
What is the essence of the arm’s length principle?
 Can you solve each transfer pricing challenge
 by applying the arm’s length principle?
What you will learn
  • The underlying principles of Transfer Pricing
  •  How to derive a classification of an entity from a functional and risk analysis
  •  The key-differences between a routine entity and an entrepreneur
  •  How to translate the abstract classification to specific types of entities along the value chain (i.e. a low risk distributor vs. a fully-fledged distributor)
  • The crucial importance of the concept and selection of the tested party in transfer pricing
Case Studies
#1 Transactional Net Margin Method (TNMM)
  • Why the TNMM is so popular
  •  What do you have to consider when benchmarking (step-by-step demo)
  •  How to interpret comparability
  •  What are the hallmarks of a good benchmark analysis and how to utilize an arm’s length range
 #2 Resale Price Method  (RPM)
  • Gross margins in transfer pricing
  • Strength of the “modified” RPM and under which conditions it is applicable
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


Module 2
Two-Sided TP Methods
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


  Date: March 18, 2019
             14:00 PM CET
  Duration: 1 hr 40 min
     Q&A: 30 min
Why you have to be extra careful when your analysis encounters intangibles and why you also
 take into account the CUP method
What you will learn
  • How to take account of intangibles in transfer pricing and how to value intangibles
  •  How to deal with intangibles in highly integrated value chains
  •  The factors for the analysis of a profit split 
  •  Understanding the importance of DEMPE
  •  Why is it difficult to establish a CUP
Case Studies
Residual Profit Split and Contribution Analysis
  • Allocation of profits (losses) commensurate with the value added contributions by the respective parties
  •  Understand why a good functional and risk analysis will account for 80% of designing a profit split
  •  Differentiate between processes of high importance and those processes merely reflecting minor value added
  •  Quantify the value added contributions of the respective parties
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


Module 3
Applying the Arm's Length Principle to
Financial Transactions and Management Services
 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


  Date: March 22, 2019
             14:00 PM CET
  Duration: 1hr 40 min
      Q&A: 30 min
How to address the new developments in financial transactions transfer pricing?
What tools can be used to analyze inter-company transactions?
What you will learn
  • OECD public discussion draft on the transfer pricing aspects of financial transactions
  •  TP aspects of inter-company loans
  •  TP aspects of cash pools
  •  OECD public discussion draft on Centralized Services
  •  Quo Vadis Benefit Test
  •  How to use safe harbor rules for low value added services
Case Studies
#1:  Intercompany Loans and Cash Pooling
  •   Step-by-step survival guides
  •  Pragmatic Excel applications   
#2:  Management Services
  •   Step-by-step survival guides
  •  Pragmatic Excel application for performing
    (and documenting) arm’s length cost allocations 

 
Virtual Tax Events
We introduced the concept of Virtual Tax Summits to bring together tax professionals and subject-matter experts to network and share knowledge in an online setting. 

Today, we boast an audience of thousands of tax professionals following our frequent events and hearing from speakers of renowned firms and institutions.


 
Online Tax Courses
Our events provide an excellent opportunity to learn more about all things tax!

We structure sessions into easy-to-follow, micro-learnings that provide up-to-date, accessible and affordable tax training 24/7.

Our growing database of 40+ hours of tax learning covers everything from transfer pricing, international tax, digital taxation and much more!


Meet Your Lecturers
Theo Elshof
Managing Director
Theo Elshof | Quantera Global

Theo is a Managing Director of Quantera Global and has more than 30 years experience in international tax, TP and tax control frameworks in roles as in-house Tax Director, head of the Dutch APA-team, Transfer Pricing director at a Big-4 firm and co-founder of Quantera Global. 

His experience includes active participation in competent authority APAs and Mutual Agreement Procedures, design, planning, implementation and defence of restructuring projects, TP controversy / audits, tax and TP control frameworks.
  
As an industry leader, Theo is a regular speaker at seminars and round tables on global transfer pricing, tax governance and transfer pricing controls and risk assessment. Theo is also a teacher at the Dutch Order of Tax Advisors.
Dr. Oliver Treidler
Founder and CEO
Dr. Oliver Treidler | TP&C

Dr. Oliver Treidler is the CEO and founder of TP&C, a transfer pricing firm based in Berlin, Germany, and an alliance partner of Quantera Global. Prior to founding TP&C, he was a Senior Manager for transfer pricing at Mazars in Berlin. 

Oliver has extensive experience in supporting his clients in designing and optimizing transfer pricing structures as well as in conducting comparability analyses and compiling documentation. Oliver subscribes to a pragmatic and business focused approach to transfer pricing. He frequently publishes articles and speaks on current transfer pricing and tax policy issues. 

Oliver holds master’s degree in international economics and European studies from the Corvinus University of Budapest (MSc.) and a Ph.D. in economics from the University of Würzburg. He also hold a Certificate as Bachelor Professional of Business Controlling.
Richard Slimmen
Managing Director
Richard Slimmen | Quantera Global

Richard is a Managing Director of Quantera Global and has more than 25 years of experience in international corporation tax and transfer pricing.

His experience includes acting as competent authority in bilateral and multilateral APAs and Mutual Agreement Procedures, designing, planning, implementing and defending complex transfer pricing structures, dispute resolution cases and audits, as well as setting up tax and transfer pricing control frameworks.

As an industry leader, Richard regularly speaks about global strategic transfer pricing risk management and transfer pricing dispute resolution. Richard also lectures transfer pricing at the International LLM Program of Leiden University.”
Included in the Course
Our growing training library 
When you become a Taxcasts member, you will get immediate access to our exclusive Tax Library which delivers 45+ hours of training videos, slide presentations, publications, and tax-related resources.

Our collection is constantly growing and includes a vareity of teaching materials that provide easy-to-access, up-to-date and affordable tax learning. 

Training videos are organied in short, concept-based clips and cateogrized into topic areas, so you can track your progress and access them anytime via web or mobile.
TP Aspects of Financial Transactions
Learn all about TP aspects of intra-group loans, guarantee fees, captives and cash pooling from a technical and jurisdictional perspective.
  

PEs and Attribution of
 Profits to PEs
Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.
  

TP Aspects of Intangible Transactions
From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.

  

TP Aspects of Financial Transactions
Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.


PEs and Attribution of 
 Profits to PEs
Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.


TP Aspects of Intangible Transactions
From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.


Taxation in a 
 Digitalized Economy
Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.


Worldwide Tax and TP Developments
Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.



Value Chain Analysis  
in TP
A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.


Taxation in a
 Digitalized Economy
Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.
  

International Tax 
Developments
Watch 10 jurisdiction-based sessions and annual overviews of global tax developments.

  

Worldwide TP
 Developments
From US Tax Reform to TP developments in various countries, stay up-to-date with what's changing in the field.
  


TP Aspects of Financial Transactions
Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.


PEs and Attribution of 
 Profits to PEs
Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.


TP Aspects of Intangible Transactions
From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.


Taxation in a 
 Digitalized Economy
Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.


Worldwide Tax and TP Developments
Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.



Value Chain Analysis  
in TP
A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.


Selected TP
Topics
Watch a varied collection of sessions covering topics such as EU State Aid, M&A TP aspects and TP documentation.
  

Value Chain 
Alignment
A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.
  

Miscellaneous
Check out the latest insights on taxation of cryptocurrencies, tax risk management and international tax career trends from professionals around the world.
  


TP Aspects of Financial Transactions
Learn how to analyze, price and test related-party financial transactions such as intra-group loans, financial guarantees, captives and cash pools.


PEs and Attribution of 
 Profits to PEs
Check out case studies of fixed-place and agency PEs, developments in digital taxation and discussions on the future of PEs.


TP Aspects of Intangible Transactions
From using DEMPE for HTVI to trade secrets and using the income approach, get practical insights on TP aspects of intangibles.


Taxation in a 
 Digitalized Economy
Hear from tax authorities, Big 4 and institutions on current policies addressing taxation in the digital economy.


Worldwide Tax and TP Developments
Watch 10 jurisdiction-based sessionsand annual overviews of global tax developments and tax technology.



Value Chain Analysis  
in TP
A step-by-step approach to value chain analysis and aspects value creation give you a solid grasp of this key concept.


Want to have access to the full course
and to 50+ hours of trainings ?

In March 13-16, 2018, we are inviting 25+ inspiring speakers to share practical insights,
lessons and experiences from their own transfer pricing and international tax projects in the post-BEPS era.

In April, 2018, we invited Dr. Vikram Chand from the University of Lausanne and Stefaan de Baets from PwC for the insights on PEs and the much discussed principles of profit attribution. 

The first Virtual Tax Summit was held from 
5 - 7 December 2017 and covered 12 sessions on TP and international tax. More than 1,000 tax professionals from more than 75 countries signed up.

This online course consists of six comprehensive sessions addressing the core aspects of taxation of cross border income in a post BEPS era. Topics covered include Principles of Taxation of Cross-Border Income,  profit attribution to DAMPE and fixed PEs, Taxation of Digitalized Business Models.
Membership Plans

Quarterly Plan

    $87
            /quarter
$87 billed quarterly
Get access to all available and upcoming content with a flexible plan of 
$87 billed every 3 months.
   

Annual Plan

    $25 
              /month*
$299 *billed annually
Save $49 by opting for the annual plan of $299/year. Access all current and upcoming learning content for one year.
   

Team Plan

Enterprise
custom billing
Grow professionally as a team. Save time and money with our group membership plan.
   
Frequently Asked Questions
Who is this online course for?
How does it work?
I can’t attend Module 1 live. Will I get a recording?
Taxcasts, Inc.
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