International Tax Programme Level 3 (WU-TA Advanced Transfer Pricing Programme)
Deepen your transfer pricing expertise with leading international academics, practitioners, industry tax leaders and tax administrators.
WU Transfer Pricing Programme
About the Programme
The WU–TA Advanced Transfer Pricing Programme brings together the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), and the Tax Academy of Singapore for an intensive four-day advanced programme in Singapore.
Covering the latest international transfer pricing developments and some of the most complex issues facing multinational businesses today, the programme combines technical expertise, practical case studies, workshops and perspectives from across academia, industry, professional practice and tax administration.
28 September – 1 October 2026 | In-Person + Virtual
Why attend?
Transfer pricing continues to evolve rapidly as businesses, tax administrations and international organisations respond to new business models, financing arrangements, intangibles, digitalisation and cross-border disputes.
Over four days, participants will explore:
Recent transfer pricing developments at the OECD and United Nations
Transfer pricing for services
Transfer pricing for financing arrangements
Transfer pricing and intangibles
Business restructurings
Permanent establishments and profit attribution
Practical challenges in benchmarking
Taxation of digital businesses
Transfer pricing in the consumer goods industry
Advance Pricing Arrangements (APA)
Mutual Agreement Procedures (MAP) and dispute resolution
Workshops and discussions are incorporated throughout the programme so participants can move beyond understanding the rules to exploring how they are applied in practice.
Who should attend?
The programme is designed for experienced professionals seeking to deepen their knowledge of transfer pricing, including those working in:
Industry and multinational enterprises
Tax and professional services
Government and tax administration
Judiciary and legal practice
Academia and research
Participants should preferably have completed Tax Academy's Level 1 or Level 2 International Tax Programmes and have at least three years of tax experience.
Programme
Day 1 — Transfer Pricing Foundations, Global Developments & Services
Monday, 28 September 2026
9.00 a.m. – 5.00 p.m.
Introduction & Recent Transfer Pricing Developments at the OECD and UN
Dr Raffaele Petruzzi
Explore:
The importance of transfer pricing
Different approaches to transfer pricing
The arm's length principle
Legal frameworks supporting the arm's length principle
Practical application of the arm's length principle
Recent developments at the OECD and UN
Transfer Pricing and Services
Ms Jow Lee Ying & Mr Zhang Zhitang
Explore:
OECD and UN approaches to services
Shareholder activities
The benefit test
Low-Value Adding Services
Shared Service Centres
Day 2 — Financing & Intangibles
Tuesday, 29 September 2026
9.00 a.m. – 5.00 p.m.
Transfer Pricing and Financing
Dr Raffaele Petruzzi
Explore:
New OECD and UN guidance
Finance companies and functional analysis
Loans
Guarantees
Cash pooling arrangements
Transfer Pricing and Intangibles
Mr Richard Goh & Mr Stephen Bruce
Explore:
Key transfer pricing issues involving intangibles
The six-step framework for analysing intangibles
Comparative case law
Approaches adopted by tax administrations
Practical takeaways
Interactive workshop
Day 3 — Restructuring, Permanent Establishments & Benchmarking
Wednesday, 30 September 2026
9.00 a.m. – 7.30 p.m.
Business Restructurings
Mr Uziel Alvarez & Mr Carlo Navarro
Explore:
Frameworks for analysing business restructurings
Key transfer pricing considerations
Court rulings
Conversion and exit tax cases
OECD Permanent Establishment Definition & Profit Attribution
Ms Yong Sing Yuan
Explore:
Permanent establishment definitions under the OECD and UN approaches
Profit attribution
Case study on profit attribution
Article 7 versus Article 9
Common Issues and Challenges in Benchmarking
Mr Falgun Thakkar
Explore:
Selecting appropriate transfer pricing methodologies
Identifying external comparables
Common benchmarking pitfalls
Data availability
Benchmarking analysis in the post-COVID environment
Technical Session & Fireside Chat
6.00 p.m. – 7.30 p.m.
An opportunity for participants to engage speakers and fellow transfer pricing professionals in a deeper technical discussion.
Day 4 — Digital Business, Consumer Goods & Dispute Resolution
Thursday, 1 October 2026
9.00 a.m. – 5.30 p.m.
Taxation of Digital Businesses
Mr Giammarco Cottani
Explore:
Typical digital business models
Practical examples
Current challenges in taxing digital businesses
International developments
How multinational structures may evolve in response
Transfer Pricing in the Consumer Goods Industry
Mr Vineet Rachh
Explore:
Transfer pricing within a multinational enterprise
Practical challenges and solutions
Principal structures
Advantages and limitations of APAs in achieving tax certainty
Dispute Avoidance & Dispute Resolution
Ms Jow Lee Ying & Ms Ng Pei San
Explore:
OECD developments and the Multilateral Instrument
Advance Pricing Arrangements
Mutual Agreement Procedures
Singapore's experience with transfer pricing dispute prevention and resolution
Learn from international and regional experts
The programme brings together speakers with experience spanning international organisations, tax administrations, multinational enterprises, professional services and academia.
Dr Raffaele Petruzzi
Managing Director, WU Transfer Pricing Center
Managing Director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU, Founder and CEO of PETRUZZI Advisory, and a member of the United Nations Subcommittee on Transfer Pricing.
Ms Yong Sing Yuan
Partner, Transfer Pricing, KPMG Singapore
A transfer pricing specialist with more than 20 years of experience in tax policy, international tax, transfer pricing and dispute resolution, including previous leadership responsibilities at the Inland Revenue Authority of Singapore.
Ms Jow Lee Ying
Senior Lecturer, Nanyang Technological University / Director, EY Singapore
An international tax and transfer pricing specialist with experience across APAs, MAPs, tax treaties and transfer pricing audits, and previous roles with IRAS, the Singapore Economic Development Board and Ministry of Finance.
Mr Falgun Thakkar
Transfer Pricing Partner, PwC Singapore
A transfer pricing specialist with more than 20 years of experience advising multinational companies across transfer pricing planning, audits, MAPs and APAs.
Mr Zhang Zhitang
International Tax Senior Manager, FrieslandCampina
A tax practitioner with experience spanning global tax planning, controversy, supply chains, intellectual property, governance and tax transformation.
Mr Richard Goh
Group Tax Specialist, Inland Revenue Authority of Singapore
A Chartered Valuer and Appraiser and Master Tax Specialist with extensive experience in transfer pricing valuation involving intellectual property and other intangibles.
Mr Stephen Bruce
Partner, EY Singapore
A financial services tax and transfer pricing specialist with 30 years of experience, including previous experience as global head of transfer pricing for an international investment bank.
Mr Uziel Alvarez
Global Head of Tax, FinTech
An international tax leader with more than 20 years of experience across London, New York, Manila and Singapore, specialising in international expansion, M&A, restructuring and operating-model transformation.
Mr Carlo L. Navarro
Head of Tax, Deloitte Philippines / Southeast Asia Transfer Pricing Leader
A leading international tax and transfer pricing practitioner with more than 25 years of experience advising multinational companies across Southeast Asia.
Mr Giammarco Cottani
Founding Partner, NOEMA Global Tax and Policy
An international tax and policy specialist with more than 20 years of experience spanning international organisations, governments and the private sector.
Mr Vineet Rachh
Asia Pacific, Middle East & Africa Tax Leader, Procter & Gamble
An international tax leader with more than 30 years of experience across Asia-Pacific, Europe and Africa, including APAs, MAPs, tax controversy and international taxation.
Ms Ng Pei San
Transfer Pricing and Dispute Resolution Branch, Inland Revenue Authority of Singapore
Leads IRAS's Transfer Pricing and Dispute Resolution Branch, covering transfer pricing policy, Advance Pricing Arrangements and Mutual Agreement Procedures with foreign tax authorities.
Programme Fees
Full Programme — In Person
Early Bird
SGD 2,092.80 inclusive of GST
Standard Rate
SGD 2,616.00 inclusive of GST
Full Programme — Virtual
SGD 1,962.00 inclusive of GST
Modular Registration
Participants may also register for individual programme days.
SGD 654.00 per module/day inclusive of GST.
Overseas Participants
Participants who, in their business capacity, belong overseas and are sponsored by overseas employers may qualify for fees excluding Singapore GST:
Early Bird: SGD 1,920
Virtual: SGD 1,800
Standard: SGD 2,400
What past participants say
“The programme provided good insights into transfer pricing developments, with content that was current and relevant, and helped to draw out key issues for discussion.”— Ms Jillian Lim, Executive Vice President, Singapore Economic Development Board
“The course trainers were knowledgeable and passionate, always providing valuable insights and feedback.”— Ms Ng Pei San, Tax Director, Inland Revenue Authority of Singapore
“The programme effectively combined academic rigor with practical insights, allowing for meaningful discussions on emerging developments and complex technical matters.”— Mr Mutukwa Sikopo, Tax Appeals Officer, Zambia Revenue Authority
About the WU Transfer Pricing Center
The WU Transfer Pricing Center (opens in new tab), based at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), researches, analyses, debates and teaches transfer pricing.
Its work brings together academic and practical perspectives with an international and interdisciplinary approach, helping bridge the relationship between transfer pricing theory and real-world practice.
About Tax Academy of Singapore
The Tax Academy of Singapore is a not-for-profit institution established by the Inland Revenue Authority of Singapore in collaboration with leading stakeholders from the tax, accounting and legal professions.
Tax Academy works with leaders from industry, academia and government to develop structured tax training programmes, seminars and conferences that strengthen the professional competency, knowledge and capabilities of the tax community.