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Transfer Pricing Programme 2023 – ADIT Cert Option

 

 

Participants may wish to complete this programme as part of their preparation for the stand-alone ADIT Certificate Exam on 13 June 2024 and 12 December 2024 – More Info

Visit our ADIT webpage for more information on the Transfer Pricing Cert Option and the full ADIT qualification.

If you wish to book this programme, please visit our dedicated store page.

Please see below the full schedule of lectures for our Transfer Pricing programme.

Date & Time Module Speakers
Session 1 – Lecture

Wed 27 September

18.00 – 20.00

Transfer Pricing Technical Update and Interpretation of Key Concepts

  • Overview of fundamental sources of transfer pricing principles
  • Review of transfer pricing legislation in Ireland
  • Recent technical updates (i.e., in last 4-5 years)
  • The arm’s length principle (ALP)
  • Functional analysis
  • Current trends
  • Examples of practical application

Sam Stiles

Session 2 – Lecture

Thurs 5 October

18.00 – 20.00

Review of transfer pricing methods and comparability

  • Summary of methods
  • Selection and application
  • Importance of comparability
  • Key considerations and challenges in relation to comparable
  • Current trends
  • Examples of practical application
Ciarán Dornan &

Dominic McNeill

Session 3 – Lecture

Thurs 12 October

18.00 – 20.00

Outline of Specific Transactions

Outline of specific transactions including:

  • Description of different types of intra-group transactions such as:
    • Intra-group services
    • Intra-group financing
    • Intangible assets
    • Business restructuring
  • Application of concepts and methods to transactions through illustrative examples
Conor O’Sullivan &

Neil Casey

Session 4 – Lecture

Wed 18 October

18.00 – 20.00

Dispute resolution and the role of documentation

  • Overview of Ireland’s requirements
  • Comparison with other jurisdictions
  • Audits and transfer pricing
  • Managing double taxation and dispute resolution procedures available (APA and MAPs)
Reenen du Preez & Lavannia

Session 5 – Workshop

Wed 22 November

18.00 – 20.00

Practical workshop to include:

  • Illustrative examples/scenarios applying material covered in Sessions 1-4
  • Review/Discussion of ADIT past papers
Anthony Crewe

Session 6 – Lecture

Wed 29 November

18.00 – 20.00

Engagement with Revenue authorities – Update to include:

  • Current areas of focus
  • Compliance interventions – illustrative examples and statistics
  • Development of Transfer Pricing in Ireland
  • Dispute resolution and mitigation
Aidan O’Connor

Session 7 – Lecture

Tues 5 December

18.00 – 20.00

Corporate and International insight

  • Alignment of transfer pricing policy with business operations
  • Dealing with permanent establishments in transfer pricing
  • Global policy developments in transfer pricing
  • Recent EU and international case law
Noel Maher

OECD

 

Our Expert Tutor Bios:

Neil Casey is a Partner in KPMG and advises many of the firm’s leading clients on transfer pricing and international tax matters across a wide spectrum including financing (debt pricing, cash pooling, financial guarantees, treasury activities), intellectual property, principal company structures, procurement and supply chain arrangements. Neil specialises in transfer pricing on matters relating to policy design, value chain analysis and dispute resolution. His principal clients operate in both the financial services sector (including aircraft leasing, banking, asset management/private equity and insurance) and non-financial services sector (including technology, energy and renewables, life sciences and real estate). Neil is a Chartered Tax Adviser (CTA) and a Fellow of Chartered Accountants Ireland.

Anthony Crewe joined Grant Thornton Ireland in April 2021 from Grant Thornton UK, where he had worked since June 2017. He heads up the transfer pricing team in Dublin and focuses on helping clients with all aspects of transfer pricing across a wide range of sectors and industries. His previous role was with the Grant Thornton transfer pricing team in London. Prior to joining Grant Thornton, Anthony spent 28 years working for HM Revenue and Customs in the UK. He is a very experienced Tax Professional, having been a specialist in many aspects of tax work, including Transfer Pricing, International Tax, Corporate Tax, Charities and Diverted Profits. He has worked with a diverse portfolio of corporate clients since joining the profession. He has supported clients in sectors including financial services, IT, automotive, aviation, pharmaceuticals and many others. He has worked with a range of clients from relatively new start-ups to very large multinational groups. During his time in HMRC, he was an International Tax Specialist, focusing on Thin Capitalisation and Transfer Pricing. He also helped to develop HMRC’s internal training programme on all aspects of international taxation. He is an experienced advocate and presenter, having represented HMRC on numerous occasions, in a variety of forums; including an OECD programme in Moscow. He is also a qualified civil and commercial mediator.

Ciarán Dornan has worked in the transfer pricing space in Ireland for six years, having joined EY in February 2020. Ciarán has previous experience as an economic researcher and policy and communications professional, liaising with government ministers to communicate and advocate for complex economic policy positions. Ciarán has worked with clients across the industry spectrum to address complex transfer pricing issues, Ciarán has specialises in  areas involving business restructuring, allocation of profits across multi-principal structures, and valuations of intellectual property.

Reenen du Preez is a Director in Deloitte Ireland’s Transfer Pricing team, specialising in dispute resolution, controversy, and financial transactions. He joined Deloitte in 2018 after relocating from South Africa. Reenen holds an undergraduate business degree in Investment Management from the University of Pretoria, followed by postgraduate degrees in Tax. He is a Chartered Tax Adviser (CTA) through the South African Institute of Tax and is currently in the process of finishing his CTA exams through the Irish Tax Institute.

Lavannia is a Senior Manager in Deloitte Ireland’s Transfer Pricing team with over 6 years’ experience supporting both domestic and multinational companies with their transfer pricing needs. She has worked with clients from various sectors, including the property, financing, energy and pharmaceutical sectors. She has experience across a broad range of projects, including business model design, controversy defence, transfer pricing documentation, MAPs and operational transfer pricing. Lavannia holds a Bachelor of Finance degree from the Australian National University and a CEMS Masters in International Management from University College Dublin/HEC Paris. Lavannia is a member of Chartered Accountants Ireland and the Irish Tax Institute.

Noel Maher is a Tax Policy Adviser with the OECD’s Transfer Pricing team based in Paris where he works on the BEPS project, the Two Pillar Solution to Address the Tax Challenges of Digitalisation, and capacity building for developing economies. Noel has represented the OECD Secretariat on Working Party 6, the FTA MAP Forum, the Task Force on the Digital Economy, and the Steering Group of the Inclusive Framework. Noel is an Economist, Chartered Tax Adviser (CTA) and a former Transfer Pricing Director with KPMG and EY Ireland where he advised predominantly Irish and US headquartered businesses in the technology and life sciences sectors. Noel has a BA and Masters in Economics from UCD.

Dominic McNeill joined EY Ireland’s Transfer Pricing practice in July 2017 having spent a number of years prior to this working in transfer pricing in Ireland. Dominic has experience in providing transfer pricing advice to multinational companies across various industries with a particular focus on financial transactions transfer pricing, including complex financial transactions, funding arrangements, extrapolation of contractual positions in the absence of legal agreements based on economic activity.

Aidan O’Connor has been working in transfer pricing roles since 2010. Aidan is currently working at the Office of the Revenue Commissioners, having joined in 2014. He is currently a Principal Officer and the Branch Manager for the Transfer Pricing Audit 2 Branch in Revenue’s Large Corporates Division. Aidan’s branch is responsible for conducting transfer pricing audit and other compliance interventions. Aidan previously worked in Big 4 practices advising Irish and overseas multinationals on a variety of transfer pricing issues for both planning and documentation purposes. He is an AITI Chartered Tax Adviser (CTA), an FCA Chartered Accountant and has a Certificate in Transfer Pricing from Chartered Institute of Taxation in the UK.

Conor O’Sullivan is a Partner in KPMG and advises major Irish Groups (public and private) and US multinationals on international tax and transfer pricing matters. He also advises key executives and shareholders on personal tax matters. His areas of expertise include debt management, financial management, IPO readiness, joint ventures, life sciences, public-private partnership and transactions. Conor is a Fellow of Chartered Accountants Ireland.

Sam Stiles is the Head of Transfer Pricing at BDO Ireland where he advises a breadth of Irish and international clients on effective transfer pricing strategy and execution. He works with clients across sectors to design, document and defend tax policies. Sam is a Fellow of the Association of Chartered Certified Accountants (ACCA) and holds a BSc (Hons) in Mathematics from the University of Leeds. He has lectured in transfer pricing at the Irish Tax Institute, at Trinity Business School, and to transfer pricing specialists across EMEA.