Amsterdam Centre for Transfer Pricing and Income Allocation

Were the sentiments of surprise regarding the outcome in the Apple State Aid case truly due to the obviousness of the “right” outcome, or were they perhaps driven by the Commission’s series of courtroom losses in similar State aid investigations? What factors set Apple’s case apart from previous State aid rulings? In response to these discussions, EU Law Live has launched a series of publications and a symposium on the Apple State Aid case, with several contributions from members and friends of the Amsterdam Centre for Transfer Pricing and Income Allocation. These contributions include: 🍎 Svitlana Buriak with “Harvest Time or Apple Grand Finale” (https://lnkd.in/emmdwxsz) 🍎 Romero J.S. Tavares, PhD with “The Poisoned Apple: Is the Court of Justice Seeking Justice through Legal Misinterpretation?” (https://lnkd.in/eNnGNEbK) 🍎 Scott Wilkie with “The Apple Case: ‘Wrong’ Questions, Misguided Answers, Regulatory Distortion?” (https://lnkd.in/enGKazVP) Each piece offers a unique perspective on the ECJ’s decision, covering different aspects and implications of the case. A big congratulations and thank you to Daniel Sarmiento, Adolfo Martin Jimenez and Sara Iglesias Sánchez for bringing this series together! This collection is now available in open access. Happy reading to all who wish to dive deeper into the nuances of this landmark ruling!

📢 Young IFA Network (YIN Netherlands) 📢 Introducing our speaker and second panelist: Svitlana Buriak (University of Amsterdam / Loyens & Loeff)! Svitlana is an assistant professor of international and EU tax law, with a focus on transfer pricing at the University of Amsterdam and the director of the Amsterdam Centre for Transfer Pricing and Income Allocation. She is also a tax advisor with Loyens & Loeff's Dutch international tax and transfer pricing team. Young IFA Network (YIN Netherlands) is organizing its annual Winter Seminar on 27 November 2024 (Wednesday). The topic: the Court of Justice of the European Union ruling of 4 October (C-585/22) on the request for a preliminary ruling asked by the Hoge Raad der Nederlanden on the (non-)compatibility of Article 10a of the Dutch Corporate Income Tax Act of 1969 with EU law, in particular the freedom of establishment. Date: 27 November 2024 (Wednesday) Time: 16:00 - 18:00 (registration 15:30), followed by social drinks Location: University of Amsterdam (Roeterseilandcampus) PE points (de Nederlandse Orde van Belastingadviseurs (NOB) the Dutch Association of Tax Advisers): 2 Registration: https://lnkd.in/e5ewQ8dm Panel: Mehdi el Manouzi (Chair) | Christophe Rabouw (Panelist) | Svitlana Buriak (Speaker/Panelist) | TBA YIN Committee: Timo Dolderman | Konstantina Tsilimigka | Marlies Baijer | Mehdi el Manouzi | Rhys Bane Young IFA Network (YIN Global) | International Fiscal Association

The video of our conference Controversy & Policy in Transfer Pricing and Income Allocation is now available! A special thank you goes to our speakers, panelists, and session chairs, who made this conference an enriching experience for all attendees. We look forward to hosting more such events in the future! #internationaltax #transferpricing #incomeallocation #tax #conference #event #actl #uva #universityofamsterdam #actp

Our webinar "Application of the Profit Split Method in the Financial Services Sector" is now online on YouTube! Ala Ursu (Hardam Ursu) and Velio Alessandro Moretti, MBA, moderated by Rezan Okten and Federico Lo Bianco, discussed the use of the PSM in asset management, banking and insurance. The discussion touched upon some key issues, such as what should be considered a KERT function, the automatization of underwriting, the peculiarity of the insurance value chain, the mismatches between art. 7 (AOA) and art. 9 (TP), and the practical challenges encountered in practice in light of three real-life case studies. Find out more: https://lnkd.in/dnpmXHFz

We are excited to reflect on the success of our recent conference, where top professionals gathered to address key issues in transfer pricing and income allocation. This event provided an invaluable opportunity to engage in discussions on emerging trends and policy challenges within the field. Held at the beautiful Campus of the Amsterdam Law School, the conference featured a diverse range of complex topics that provoked debates and generated new insights. The event showcased the growing community of experts and practitioners dedicated to advancing both the theoretical and practical aspects of the discipline. A special thank you goes out to our speakers, panelists, and session chairs, whose contributions made this conference an enriching experience for all attendees. 🔸 Panel 1: Raffaele Russo, Isabel Verlinden, Clive Jie-A-Joen, Önder Albayrak, Paolo Valerio Barbantini 🔸 Panel 2: Sjoerd Douma, Natalie Reypens, Federico Lo Bianco, Yves Hervé, Umberto Lorenzi 🔸 Panel 3: Svitlana Buriak, Nate Zahnd, Dr. Giammarco Cottani, LL.M, Martin Lagarden, Anna Stepniak 🔸 Panel 4: Rezan Okten, Olga Shambaleva, Dr. Kerim Keser, Ala Ursu (Hardam Ursu), Velio Alessandro Moretti, MBA 🔸 Panel 5: Richard Collier, Peter Wattel, M.C. (Martin) de Graaf, Marc Clercx 🔸 Panel 6: Richard Collier, Mayra O. Lucas Mas, Jérôme Monsenego, Monique van Herksen, Michael Lennard 🔸 Panel 7: Anna (Anya) Vvedenskaya, Iris Burgstaller, Zofia Mika, Monique van Herksen As we continue to strengthen this community, we are committed to fostering dialogue, collaboration, and innovation in this dynamic field. We look forward to hosting more such events in the future! With warmest regards, Svitlana Buriak on behalf of the Amsterdam Centre for Transfer Pricing and Income Allocation

Tomorrow, in the fourth panel of our conference "Controversy & Policy in Transfer Pricing and Income Allocation" we will discuss "Business exit: tax considerations and valuations". When a company exits a jurisdiction and/or relocates certain assets, redeploys functions, transfers economically significant risks, or shifts profit potential to another jurisdiction, it may trigger an exit charge on the perceived value of the transferred business. Even minor changes in the business operating model can potentially result in an exit tax. To minimize risks and ensure compliance, a careful analysis must be conducted early in the business restructuring process to evaluate whether an exit charge is due and to determine the value of the transferred business. Session 4 discusses the circumstances under which there is an exit tax and the relevant case law, the critical aspects of business valuation, the importance of ex-ante and ex-post functional analysis, the role of realistically available options and group synergies, the potential inclusion of indemnity and compensation clauses, and the challenges related to post-restructuring and substance. Chair: Rezan Okten (Dentons, Netherlands / Universiteit van Amsterdam) Keynote: Olga Shambaleva (LIPTON Teas and Infusions, Netherlands) Speakers: Dr. Kerim Keser (Kroll Deutschland) Ala Ursu (NXP Semiconductors, Netherlands) Velio Alessandro Moretti, MBA (Generali, Italy)

Doe iets wat ertoe doet | Do something that matters We are ready for our event and excited to welcome our speakers and guests! Good weather is included in the conference package ☀️ The Conference of the Amsterdam Centre of Transfer Pricing and Income Allocation in ... 23 Hours 37 Minutes 25 Seconds #transferpricing #actp #uva #internationaltax

What a Graduation Day it was! So proud of our graduates of the Adv LLM Program in International Tax Law at the University of Amsterdam. The day started with personal diploma ceremonies, followed by the alumni symposium on international tax policy with key note speeches by Maarten Floris de Wilde and Tiago Cassiano Neves and panel contributions by Mattia Calabrese, Nupur Gupta, Ludovico Carpanetto and Fernanda Moura. The panels were chaired by Svitlana Buriak and Giorgio Beretta. The traditional Graduation Lecture in the historical Agnietenkapel was delivered by Femke Groothuis who spoke about the need to rebalance the tax mix to support future-proof business models. The annual award for the graduate with the highest average grade was granted to Afonso Costa Gomes. The thesis awards went to Marija Zvonarjova for her thesis on the Applicability of OECD-developed GloBE Explanatory Materials within the Legal Framework of the European Union and to Afonso Costa Gomes for his thesis on the Cross Border Transfer of Going Concern: How to Prevent VAT Distortions When Applying the TOGC No Supply Rule across Different Member States? Honourable mentions were granted to davide affatigato for his thesis on Dispute Resolution under Pillar Two and to Opal Ho for her thesis on Strengthening VAT Administrative Cooperation between the EU and Third Countries. The great speech on behalf of the class of 23/24 was delivered by Brian Borg and Marija Zvonarjova, followed by a reception where the new incoming students were able to meet our graduates. Just before the graduation dinner, Daniēl S. Smit gave a small piano concert in honour of the 23/24 class, followed by a toast by Otto Marres. The heartwarming video prepared by the class, shown during dinner, was presented by Marc-Nikolay Popov. What a great group this was! Many thanks to all and especially also to Vassilis Dafnomilis, Anna (Anya) Vvedenskaya, Claudio Cipollini, Juan Manuel Vazquez, Mariken van Hilten, Frans Sonneveldt, Rezan Okten, Raffaele Russo, Piet Seidenberg and Vishay Nohar. This has been a true team effort. https://lnkd.in/ew5C7VnS

The increasing awareness of an incoming environmental crisis is steering multinational companies toward greater attention to sustainability practices. ESG values are at the centre of attention not only because they are believed to be one of the key future sources of competitive advantage but also because they may lead to disruptive changes in the MNEs' value chains. These disruptive changes will inevitably lead to a modification of the intercompany arrangements, and session 7 aims to unveil the main challenges that such changes involve not only in the TP documentation and compliance but also for the broader reorganization projects of supply chains. Chair: Anna (Anya) Vvedenskaya (Universiteit van Amsterdam / EY) Speakers: Iris Burgstaller (TPA Austria) Dr. Stefan Greil (Ministery of Finance, Germany) Zofia Mika (Mika Tax Solutions) Monique van Herksen (Simmons & Simmons / United Nations)