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Welcome to the Amsterdam Center for Transfer Pricing and Income Allocation

The Amsterdam Centre for Transfer Pricing and Income Allocation (ACTP) is an initiative of the Amsterdam Center for Tax Law at the University of Amsterdam. Our mission is to bridge the gap between academic research, tax policy, and business practice in the field of transfer pricing and international income allocation.

On 17-18 September, the ACTP biennial conference returns for its 3rd edition, bringing together tax professors and leading scholars, government officials, and senior tax professionals for two days of in-depth discussion on the questions that matter most: how transfer pricing rules are evolving, how they are being applied, and where they are heading next.

Program
Conference Program
Thursday-Friday | 17-18 September 2026

The full list of speakers will be announced soon!
Sept. 17, 2026
13:30-14:15
The digital economy: Back in the spotlight?
Opening discussion | Invited speaker (to be announced)
Discussants: Dr. Svitlana Buriak & Dr. Richard Collier
With Pillar One effectively stalled and DSTs proliferating, are we back to square one? Can the arm's length principle allocate taxing rights over digital value creation, or do we need a fundamentally different approach? Is a new multilateral approach still feasible?
Sept. 17, 2026
14:15-15:30
ALP today: What are the biggest policy issues?
Panel 1 | Chair: Hans van Egdom
How does the ALP cope with the proliferation of AI-driven services and digital business models that blur the line between routine and high-value functions? How should transfer pricing respond to crisis and distress scenarios, tariff shocks, and forced supply chain restructurings that have no arm's length precedent? What will the OECD's forthcoming Chapter VII revision on intra-group services change for the benefit test and the pricing of services that generate significant value? These and other main policy issues facing the ALP today.
Sept. 17, 2026
16:00-17:30
Where the guidelines fall short: Practice vs principle
Panel 2 | Chair: Isabel Verlinden
Building also on the policy issues identified in Session 1, this panel asks: where do the OECD Guidelines deviate from practice, and where is more guidance needed? The control over risk framework, the migration of intangibles, intra-group services, PE and workforce mobility, financial transactions, and value chain transformations all expose areas where taxpayers and tax administrations need clearer answers.
Sept. 18, 2026
09:00-10:30
Non-recognition: The boundaries of commercial sense
Panel 3 | Chair: Prof. Cees Peters
Where should the line be drawn between the actual transaction as structured by the parties and a reconstituted transaction based on what independent parties would have agreed? How do we reconcile entrepreneurial freedom with the need to ensure arm's length outcomes? What role does the burden of proof play, and how material must a pricing deviation be to warrant penalties? 
Sept. 18, 2026
11:00-12:30
Transfer pricing case law in motion
Panel 4 | Chair: Lucia Sahin
What are the most consequential recent transfer pricing rulings? How are courts shaping the treatment of intangibles, business restructurings, PE in franchise arrangements, and intra-group financial transactions?
Sept. 18, 2026
14:00-15:30
Transfer pricing in the EU: Any hope for certainty?
Panel 5 | Chair: Prof. Sjoerd Douma
With the TP Directive withdrawn, what will the Tax Omnibus change for transfer pricing? Does ALP compliance prevent abuse, or can ATAD still apply on top? And why does the misalignment between transfer pricing, VAT, and customs remain unresolved?
Sept. 18, 2026
16:00-17:30
Dispute prevention & resolution: What works & What does not?
Panel 6 | Chair: Prof. Frank Pötgens
Which dispute resolution instruments actually deliver timely outcomes, and which do not? What can we learn from the tax audit practice and recent MAP experience? Does the OECD's 2026 MEMAP change anything in practice? And is tax insurance becoming a viable tool for managing transfer pricing risk?
The academic committee
  • Dr. Richard Collier
    Research Fellow ACTP |
    Associate Fellow Oxford University
  • Dr. Svitlana Buriak
    Director ACTP |
    Assoc. Professor University of Amsterdam
  • Dr. Federico lo Bianco
    Research Fellow ACTP |
    Postdoctoral researcher UKE

Location & Venue

  • Address

    Amsterdam Law School, De Brug
    Nieuwe Achtergracht 166, 1018 WV
    Google Maps

  • Main entrance

    In the photo, the main entrance to the building can be seen.

  • Venue - "De Brug" Hall

    After the Main entrance, turn left, and head to the elevator or the stairs. Go to the 4th floor.

Location

  • Address

    Amsterdam Law School, De Brug
    Nieuwe Achtergracht 166, 1018 WV
    Google Maps

Contact

Dr. Federico Lo Bianco
f.m.lobianco@uva.nl
Research Fellow
University of Amsterdam
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