“Transfer pricing is an art, not an exact science.” This statement by an OECD expert during a class left a deep impression on Zheng Xinyue, a student in the 2024 cohort of the China-OECD LLM Programme on Taxation (COTP).

Intensive Learning with OECD Experts

Recently, COTP witnessed a month - long teaching session by tax law experts from the Organization for Economic Co - operation and Development (OECD). Chinese and international students in the 2024 cohort engaged in vibrant discussions and in - depth reflections on the latest international tax law issues. The interactions significantly deepened their understanding of complex tax concepts.

Established by Xiamen University in collaboration with the State Taxation Administration of China, the Ministry of Finance, and the OECD, COTP represents Xiamen University’s first initiative in cross -national ministries and commissions and international organizations as it embarks on its new centenary journey. Since its launch in 2022, COTP, leveraging its partnership with the OECD, has emerged as a premier platform for nurturing international tax talent, serving China and other developing countries.

Multifaceted Curriculum of COTP

In March, four senior OECD consultants visited Xiamen University. They delivered two core courses—“International Tax Agreements” and “Transfer Pricing”—as a three - week on - site teaching session for COTP students.

Néstor Venegas and Edward Barret, seasoned experts from the OECD Centre for Tax Policy and Administration, imparted their extensive knowledge on tax agreement negotiations, applications, and interpretations. Meanwhile, Noel Maher and Kenjiroh Tomita guided students through the “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations,” enhancing students’ understanding of the arm’s - length principle and transfer pricing analysis.

Students lauded the face - to - face exchanges with OECD experts, which broadened their perspectives and deepened their grasp of advanced tax concepts. Mr. Venegas commended COTP students for their high level of engagement and professional acumen, stating that cross - cultural communication among students and tax officials is fostering knowledge sharing and innovation in the international tax arena.

Looking ahead, COTP plans to invite a diverse range of experts, including those from the State Taxation Administration, the “Big Four” accounting firms, leading foreign - related enterprises, top universities, and other international organizations. This initiative aims to provide students with exposure to the latest tax knowledge and practical insights.

Hands - on International Organization Experience

COTP emphasizes practical experience, believing that “true knowledge comes from practice.” To this end, the program actively facilitates international internships.

Wu Jinlan, an intern at the OECD, shared that applying classroom knowledge in a global setting has sharpened her career focus. Since January 2025, the internship practice agreement signed between the COTP and the OECD has officially come into effect. Four students will be selected each year to intern at the OECD headquarters in Paris for three months. Xu Lingyan and Wu Jinlan, members of the 2022 cohort, have already completed their internships in Paris, gaining valuable insights into international tax governance. In April 2025, SANTOS JOHN TERRY and MAKMOT VICTOR PHILIP OYENA from the 2023 cohort will embark on their Parisian internships.

COTP students have also interned at the United Nations. Zhao Canchang, a 2022 - cohort student, interned at the UN headquarters in New York from July to October 2024. More recently, Tang Luyao and Wu Pengyao from the 2023 cohort conducted research at the Austrian and International Tax Law Centre at the Vienna University of Economics and Business.

COTP’s commitment to exploring international tax issues and facilitating international organization experiences aligns with national development strategies, contributing to the cultivation of high - level global governance talent. Moving forward, COTP will maintain its high - standard operations, nurturing top - tier tax professionals well - versed in international tax regulations, and thus contribute to China's participation in the construction of the global tax governance system.

[Article by Dong Xiaoqing, Photos by Dong Xiaoqing, Zhao Canchang, etc. ]

The Chinese Version please refer to: 探究国际前沿问题，投身国际组织实践：COTP中外学子这样与世界对话