ONLINE JOB lecture ‘The profit split method: the latest developments and its use in practice’ on 24 June 2021

LET OP! DEZE LEZING ZAL IN HET ENGELS WORDEN GEHOUDEN.

On Thursday 24 June 2021, the Tax Knowledge Committee (Commissie Vaktechniek) is hosting the online JOB lecture: ‘The profit split method: the latest developments and its use in practice’.

The profit split method is one of the five broadly accepted transfer pricing methods, which are used to ensure that terms and conditions of transactions between related companies occur on an arm’s length basis. The JOB lecture, after a recap of the theoretical background, will focus on applying the profit split method using several case studies. While doing that, the strengths, the weaknesses and the main challenges of applying the profit split method will also be addressed. Furthermore, the latest developments around the profit split method and the impact of the BEPS project will be covered. The lecturers will also briefly explore the Dutch tax authorities' policy regarding the applicability of the profit split method.

The guest speakers for the online JOB lecture are Rezan Ökten and Koen Bolink.

Rezan works as Transfer Pricing Counsel at Houthoff. In his daily practice, he advises multinational companies on all issues relating to transfer pricing. Before joining Houthoff, he worked as a global in-house transfer pricing specialist at two of the largest technology and telecommunications companies in the world (Liberty Global and VEON). Rezan is also a lecturer at the University of Amsterdam where he teaches transfer pricing on the Advanced LL.M. programme in International Tax Law. He regularly teaches transfer pricing masterclasses at IBFD. He has also written a number of articles focusing on the transfer pricing aspects of intangibles and cost contribution arrangements. He is co-author and author of two transfer pricing books.

Koen works as Senior Associate in Transfer Pricing at Houthoff. He advises various multinational companies on their transfer pricing matters, with a particular focus on corporate restructuring, attributing profit to permanent establishments and allocating head office costs. He has frequently been involved in concluding Advance Pricing Agreements ("APAs") with the Dutch tax authorities and recently wrote an article on the publication of anonymized summaries of APAs and APA requests under the revised Dutch tax ruling practice.

If participants with limited knowledge about transfer pricing would like to learn more in advance, they can prepare by reading:

• Section C Transactional profit split method, Part III: Transactional profit method (p. 117 – 145) of the OECD’s Transfer Pricing Guidelines; and
• the OECD’s Revised Guidance on the Application of the Transactional Profit Split Method: Inclusive Framework on BEPS: Action 10, OECD/G20 Base Erosion and Profit Shifting Project (2018).

This is not mandatory.

Location
Due to the COVID-19 measures, the JOB lecture will be held online.

Signing up
The lecture is only intended for JOB members. You can register via your Personal Page or via the registration link at the bottom of this page.

Platform
This lecture is offered in MS TEAMS. Participants will receive a login link a week before the start of the lecture.