1. How to apply for the EPTP?

The future participants need to access the registration form on line. (link)

Participants are required to fill and submit it along with their CV's by February 14th, 2024

2. What is the target audience of the EPTP?

- Members of tax and finance teams in a MNE;

- Professionals from various service lines in consulting firms (especially international corporate tax & transfer pricing);

- Senior level employees of fiduciaries;

- Associates and partners from law firms;

- Tax authorities and academics;

- Accountants, economists and professionals working in similar areas.

3. How much does the EPTP cost?

The tuition fee for the Executive Program in Transfer Pricing is CHF 10'500 (includes documentation).

  • There is a discount of 20% if the participants apply before October 31st, 2023
  • There is a discount of 10% if the participants apply before December 15th, 2023

4. How many participants will be admitted in the EPTP?

The number of places is limited. Participants will be admitted on a first come first serve basis.

5. What is the course duration?

The program is organized on a part time basis from March 2024 to November 2024 (with a holiday break in July and August). The classes are held on Thursday, Friday and Saturday once a month. The technical paper has to be written and submitted by November 30th, 2024.

6. The EPTP will be conducted in which language?

The teaching and reading material provided in the program is in English.

7. Who is the program faculty?

All topics are addressed from a theoretical and practical perspective and are illustrated though numerous case studies. The sessions are taught by senior members of international policy making organisations (such as the OECD), government officials, senior practitioners from international consulting/law firms, in house tax directors from leading multinationals, academics, senior economists and members of the tax administration. More information can be found here

8. What material will be provided during the course?

The reading material consists of the OECD Transfer Pricing Guidelines, UN Transfer Pricing Manual, US Transfer Pricing regulations. It also consists of articles from leading journals and chapters from various books. The material will be provided through an online platform. Participants will be required to print the material and bring them to the classroom.

9. What kind of evaluation do the participants have to undergo in order to complete the EPTP?

Participants need to attend 80% of the classes. To complete their training the participants will be required to write a short technical paper on Transfer Pricing topic. This technical paper should be between 5'000 and 8'000 words. The paper has to be written under the supervision of the program directors or by one of the faculty members.

10. When can a participant do research for the technical paper?

Participants can carry out their research at the ISDC - Institut Suisse de Droit Comparé in Lausanne. Available on the following link. or at the Library of the University of Lausanne (link)

12. Does the EPTP provide accommodation for foreign participants?

If you would need to stay in a hotel during the course, we will be happy to provide you a list with hotels nearby. Please feel free to contact us.


13. How will the courses be delivered ?

The ninth edition will be delivered onsite at the University campus
Important :The participants have to come to Switzerland to follow the classes as we will not offer on-line and we will not record the session.


11. Will the research paper be published ?

Several research papers of the participants have been published in international journals. For example, see the following contributions published under the supervision and guidance of Prof. Dr.  Vikram Chand :


Tamara Schwärzler: Using the Capital Allocation Approach to Attribute Capital to a Permanent Establishment, International Transfer Pricing Journal (IBFD), March 22nd, 2017

Giulio Vernia: Transfer Pricing Documentation for Permanent Establishments, International Transfer Pricing Journal (IBFD), April 20th, 2017

Alexandra Wintsch: Attribution of Profits to Permanent Establishments: The 2008 Article 7 versus the 2010 Article 7 of the OECD Model Tax Convention, International Transfer Pricing Journal (IBFD), August 15th, 2017

Rebecca Critchley: Dispute Prevention Avenues for Permanent Establishments, International Transfer Pricing Journal (IBFD), July 19th, 2017

Alexander Haller: Physical cash pooling in a negative interest rate environment, Kluwer Tax Blog, March 19th, 2018

Piotr Drobnik: The Attribution of Profits to a Dependent Agent PE – If the Dependent Agent Is a Commissionaire (Wholly Owned Subsidiary) of the Principal, International Transfer Pricing Journal (IBFD), April 2018

Jean-François Dutriez: Attribution of Profits to a Permanent Establishment of a Company Engaged in Online Sales of Goods through a Local Warehouse, International Transfer Pricing Journal (IBFD), April 2018

Lukas Stähli: The Use of the Profit Split Method in Highly Integrated Transactions, International Transfer Pricing Journal (IBFD), June 2018

Cansu Bagran Ilhan: The Use of Value Chain Analysis in a Profit Split, International Transfer Pricing Journal (IBFD), June 2018

Selina Reif: The Fundamental Approach for Allocation of Risks and Returns for Financing Entities available, Kluwer tax blog, July 12th, 2018

Adam Kosmala: Transfer Pricing Aspects of Performance Guarantees, Kluwer Tax Blog, July 27th, 2018

Karin OttoTransfer Pricing: Accurate Delineation of the Captive Insurance Arrangement – Is the OECD Guidance Clear on this Matter?, Kluwer Tax Blog, September 26th, 2018

Alexander Haller: Applying the Arm’s Length Principle to Physical Cash Pooling Arrangements, Intertax journals (Kluwer law online), volume 47, issue 4, April 2019

Lukas Stälhi Does the Transactional Profit Split Method Apply to Centralized Business Models?, Kluwer Tax Blog , July 31st, 2019

Adam KosmalaApplying the Arm's Length Principle to Performance Guarantees, Cole R. T., Byrnes W. H. (eds.) Lexis’ Practical Guide to U.S. Transfer Pricing chap. 35, Lexis Nexis , 08, 2019

Cristina Zenha Rella: International - Central Procurement Operating Models in a Multinational Group, International Transfer Pricing Journal (IBFD), September 2019

Aurora Ferraton: Location-Specific Advantages & Transfer Pricing, International Transfer Pricing Journal  (IBFD), October 9th, 2019

Alissa Fedi: Transfer Pricing Aspects of Transactions with Marketing Intangibles in Post BEPS World, International Transfer Pricing Journal (IBFD), November 12th, 2019

Emanuela Buono: Transfer Pricing Aspects of Intra Group Services: What are the Open Issues and What Can Be Improved? International Transfer Pricing Journal (IBFD), November 27th, 2019

Catharina Gramm: Profit Attribution to a Fixed Place Permanent Establishment: Case Study - Showroom, International Transfer Pricing Journal   (IBFD), February 4th, 2020

Louis Ballivet: Use of Non-Arm's Length Approaches within the Arm's Length Principle : Heading toward a New Standard ?, International Transfer Pricing Journal   (IBFD), February 4th, 2020

Serena Picariello (with Prof. Dr. Vikram Chand): The Use of Country-by-country reporting for tax risk assessment : Challenges and potential solutions, International Tax Studies Journal (IBFD), February 14th, 2020

Denis Amici: In depth analysis of the concept of Options Realistically Available in Transfer Pricing, International Transfer Pricing Journal  (IBFD), February 25th, 2020

Simon Hoffmann: Hard-To-Value-Intangibles and the pricing of uncertainty, International Transfer Pricing Journal (IBFD), April 6th, 2020

Gautier Vallat: Application of the DEMPE concept in the Pharmaceutical Industry, International Transfer Pricing Journal (IBFD), April 8th, 2020

Valentin Rolle: Arbitration in Transfer Pricing : Issues and solutions, IFF Forum für Steuerrecht, Universität St Gallen, 2020/2

Sébastien Maury: Applying the arm’s length principle to group synergies, International Transfer Pricing Journal (IBFD), June 16th, 2020

Philipp Goppelsroeder: Does the Profit Split Method apply to principal structures – In depth analysis ?, International Transfer Pricing Journal (IBFD), June 23rd, 2020

Céline MartinSwiss Supreme Court Restates Principles of International Profit Allocation under Swiss Domestic Law, Kluwer tax blog, October 9th, 2020

Suthida LeelaphaibonnsakulProfit Attribution to a Construction Permanent Establishment : Numeral Case Study, International Transfer Pricing Journal (IBFD), November 2nd, 2020

Natassia Burkhalter-Martinez : Transfer Pricing Aspects of Intragroup Financial Guarantees in Light of the Recent OECD TP Guidance on Financial Transactions, IFF Forum für Steuerrecht, Universität St Gallen, 2020/4

Fabian ArnoldIn depth analysis of the concept of control over risk, International Transfer Pricing Journal (IBFD)December 9th, 2020

Giovanni Lembo (with Prof. Dr. Vikram Chand) : Intangible-Related Profit Allocation within MNEs based on KeyDEMPE Functions: Selected Issues and Interaction with Pillar One and Pillar Two of the Digital Debate, International Tax Studies Journal (IBFD), December 2020

Anja Benz : Practical application of the guidance on low value-adding services – Case study, International Transfer Pricing Journal (IBFD)February 4th, 2021

Thomas Petrakos (with Prof. Dr. Vikram Chand and Mrs. Amanda Pletz): Interest rate benchmarking : A comparison between the loan and the bond approach, International Transfer Pricing Journal (IBFD), June 18th, 2021

Javier Garcia Berdonce (with Prof. Dr. Vikram Chand and Prof. Dr. Xaver Ditz) : Answering Eight Key Questions about Transfer Pricing during the COVID-19 EraInternational Transfer Pricing Journal (IBFD), July 6th, 2021

Céline Martin, Natassia Burkhalter and Prof. Dr. Vikram Chand : Arm's Length Principle from a Swiss Perspective: Profit Allocation to Inbound and Outbound Permanent Establishments, Intertax journals (Kluwer law online), volume 50, issue 1, 2022

Alexia KardachakiResolving multilateral transfer pricing disputes under the current tax treaty and European frameworks: shortcomings and possible suggestions for improvement, International Transfer Pricing Journal (IBFD), January 6th, 2022

Emilia Siravo (with Prof. Dr. Vikram Chand and Mr. Gerhard Foth) : Risk Management at a Time of Systemic Uncertainty: Transfer Pricing Implications of Intra-Group Reinsurance Quota Share Arrangements, International Tax Studies Journal (IBFD), March 4th, 2022

Rodrigo Ruberti : Applying the AOA to a PE that performs services : a case study that develops the balance sheet and the profit and loss account of the branch (which also takes into account internal dealings), International Transfer Pricing Journal ( (IBFD), April 6th, 2022

Timo ProkophApplying the ALP to high risk and low risk financing / treasury entities – case study, International Transfer Pricing Journal (IBFD), April 25th, 2022

Giacomo RossiReview of Benchmark Analysis during COVID-19: Case Study Analysis in Three Industries Particularly Affected by the Pandemic, International Transfer Pricing Journal (IBFD), May 25th, 2022

Nathanael ZahndIntragroup IP Transfers Following International M&A Transactions - Challenges and Best Practice From a (Swiss) Transfer Pricing Perspective, International Transfer Pricing Journal (IBFD), May 3rd, 2023

Carmen Roth : Analyzing recent leading Transfer Pricing cases: What trends emerge?, International Transfer Pricing Journal (IBFD), May 11th, 2023

Thomas Hoppe : The EU Public Country-by-Country Reporting – A Case Study on Tax Risk Assessment, International Transfer Pricing Journal (IBFD), January 25th, 2024

Velio Moretti : Key transfer pricing issues arising from remote working and employee mobility in a Post-Covid world, Forthcoming

Ana Filipa Vieira Nadais : US Court Cases and Intangible Assets Valuations, International Transfer Pricing Journal, April 17th, 2024

Nataliia Guzenko : Recent case law on the application of the profit split method, International Transfer Pricing Journal, May 8th, 2024

Philippe Gobet : Profit Attribution to Permanent Establishments Without Personnel under the AOA: A Systematic Analysis of OECD Literature and Recent Developments in Germany, International Transfer Pricing JournalJuly 3rd, 2024



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