Danny Oosterhoff is a transfer pricing partner leading EY’s international tax and transaction services practice in the Western Europe Maghreb (WEM) area. Danny has specialized in transfer pricing services since 1996 and joined Ernst & Young’s economic consulting practice in Chicago for one year in 1998 as a member of the European transfer pricing desk.
He has worked with many multinational enterprises in the field of transfer pricing planning, transfer pricing implementation, risk management and dispute resolution. His experience covers a wide range of industries, including chemicals, pharmaceutical, high-tech and technology, consumer products, services, media, digital platforms and telecommunication sectors. He has negotiated a significant number of Advance Pricing Agreements with the Dutch authorities, both on a unilateral and multilateral level. He has also effectively used APAs and roll-back mechanisms to resolve transfer pricing disputes and worked on numerous international controversy cases.
Danny has extensive experience in business restructuring and business model alignment including the transition to digital operating models. He supports companies with the design, optimization and implementation of transfer pricing systems that align business, legal and tax objectives. He has advised many global companies with their tangible, intangible, service and financing flows in relation to operating model optimization.
In addition to operating model changes, he assists many companies on transfer pricing risk management, including providing support in defining the corporate transfer pricing function and associated risk management processes. Transfer pricing risk management support entails the overall transfer pricing strategy including development of transfer pricing policies and risk frameworks with effective control mechanisms. The implementation of a risk framework is instrumental in identifying, qualifying and quantifying transfer pricing risks and establishing processes and procedures to manage such risks. The governance and communication aspects around transfer pricing policies have become an important part of his role as a transfer pricing adviser.
Danny has also worked with many international companies on the transfer pricing aspects of acquisitions and divestures. For many multinational enterprises, he has assisted in both the field of due-diligence and post-merger integration of transfer pricing policies and alignment of operating models. An important part of his role in these and other transfer pricing implementation projects is to reconcile business drivers, management performance aspects, systems capabilities, transfer pricing regulatory aspects and overall tax policies and tax strategies.
Furthermore, Danny is a frequent contributor to Dutch and international professional journals on a variety of transfer pricing matters and regularly speaks at forums and events about transfer pricing and tax effective supply chain management.Danny Oosterhoff holds a degree in tax law from the University of Tilburg.
The Dutch approach to the arm's length principle has always kept pace with the evolving international interpretation, and arguably in certain aspects has even been ahead of its time. The OECD guidance around alignment between the actual controlling of risks with the contractual division of risks, as...