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Frequently Asked Questions


1. How to apply for the EPTP?

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


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 9'500 (includes documentation).

  • There is a discount of 20% if the participants apply before September 30th, 2020
  • There is a discount of 10% if the participants apply before November 30th, 2020

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 February 2021 to October 2021. The classes are held on Thursday, Friday and Saturday once a month between February and July. The technical paper has to be written and submitted by October 31st, 2021.

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.

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 Dr. Vikram Chand :


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

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

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

Cansu Bagran Ilhan : C.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 Kosmla : Transfer Pricing Aspects of Performance Guarantees, Kluwer Tax Blog, July 27th, 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

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

Aurora Ferraton : A. FerratonLocation-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 : 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

Roland Britt : In Depth Analysis of Incidental Benefits, International Transfer Pricing Journal (IBFD), Forthcoming

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.





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