Global Transfer Pricing Course

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Content Course Overview

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Target Group

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Period3 General Information

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Content and Structure

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Lecturers6 Lunches, Coffee Breaks, and Others

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Course Materials

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Course Level and Prerequisites

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Venue10 Course Fees

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Questions and Contact

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Registration12 Application form

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Course Overview The increasing global trade and the role of multinational enterprises in the global economy have boosted the relevance of transfer pricing topics. The number of countries having transfer pricing legislation in place has increased from a mere four in 1994 to more than 80 in 2014. Therefore, transfer pricing is one of the most relevant and challenging topics in the international tax environment. The Global Transfer Pricing Course offered by the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business (WU, Vienna (Austria)) (www.wu.ac.at/ en) meets the increasing demands for education in this field by offering high quality training. With renowned experts from all over the world as lecturers, training at the highest international level with a great degree of practical relevance is guaranteed. The Institute for Austrian and International Tax Law (www.wu.ac.at/taxlaw/en) is one of the global leading tax academic institutions and is extremely active in the field of international taxation. As well as research and teaching activities, its staff participate in numerous national and international tax projects and over the years has developed an impressive network of contacts in more than 90 countries. The Institute’s team comprises of 60 academic staff members as well as many visiting professors and guest researchers from around the world.

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WU Campus © Johannes Zinner

Target Group The course is targeted at professionals around the world who want to build or broaden their knowledge in transfer pricing. Participants are typically tax and transfer pricing advisors (accountants, economists, and lawyers), in-house tax and finance employees of international companies, government officials, and academics.

Period This 5-day course will be held on May 18-22, 2015.

General Information The course is entirely held in English. In order to guarantee a high degree of interactivity, the course is limited to a maximum of 30 participants. Early registration is therefore recommended. The course is structured in four sessions per day of 1,5 hours each. Each topic is analyzed with a mix of theory and workshops (with case studies).

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Content and Structure Monday, May 18, 2015 Introduction to Transfer Pricing; Transfer Pricing and Attribution of Profits to Permanent Establishments 09.00-10.30 Introduction to Transfer Pricing (First Part) The importance of transfer pricing; what is transfer pricing; different approaches to transfer pricing (arm’s length principle, formulary apportionment, safe harbours); the arm’s length principle; the legal framework Raffaele Petruzzi 11.00-12.30 Introduction to Transfer Pricing (Second Part) Arm’s length principle and comparability analysis; transfer pricing adjustments (primary adjustments and corresponding adjustments; primary adjustments and secondary adjustments); transfer pricing penalties Helmut Loukota 14.00-15.30 Transfer Pricing and Attribution of Profits to Permanent Establishments (Excluding Issues of Existence of Permanent Establishments) Hans Pijl 16.00-17.30 Workshop: Practical Application of Transfer Pricing and Attribution of Profits to Permanent Establishments Hans Pijl

Tuesday, May 19, 2015 Transfer Pricing Methods 09.00-10.30 Introduction to Transfer Pricing Methods and Their Selections Most appropriate method vs. best method; use of more than one method; benchmarking Traditional Transaction Methods Comparable uncontrolled price method; resale price method; cost plus method Axel Eigelshoven 11.00-12.30 Workshop: Practical Application of the Transfer Pricing Methods (First Part) Axel Eigelshoven and Marta Pankiv 14.00-15.30 Transactional Profit Methods Transactional net margin method; transactional profit split method Other Methods Safe-harbours; sixth-method; use of financial valuations Sebastien Gonnet 16.00-17.30 Workshop: Practical Application of the Transfer Pricing Methods (Second Part) Sebastien Gonnet and Romero Tavares

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Wednesday, May 20, 2015 Administrative Approaches to Avoiding/Minimizing and Resolving Transfer Pricing Disputes 09.00-10.30 Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes Rulings and Advanced Pricing Agreements (APAs); safe harbours; simultaneous tax examinations Giammarco Cottani 11.00-12.30 Workshop: Practical Application of the Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes Giammarco Cottani and Judith Herdin-Winter 14.00-15.30 Administrative Approaches to Resolving Transfer Pricing Disputes Mutual Agreement Procedures (MAPs); arbitration (conventional, baseball, EU arbitration) Monique van Herksen 16.00-17.30 Workshop: Practical Application of the Administrative Approaches to Resolving Transfer Pricing Disputes Monique van Herksen and Elena Variychuk

Thursday, May 21, 2015 Transfer Pricing Risk Management and Compliance; Transfer Pricing in Specific Geographic Areas 09.00-10.30 Transfer Pricing Risk Management and Compliance Transfer pricing risk management; transfer pricing documentation (master file, local file, country-by-country report) Sven Bremer 11.00-12.30 Workshop: Practical Application of Transfer Pricing Risk Management and Compliance Sven Bremer and Raffaele Petruzzi 14.00-15.30 Transfer Pricing in Specific Geographic Areas (First Part) Transfer pricing at the OECD (including current BEPS project) Joel Lachlan Cooper 16.00-17.30 Transfer Pricing in Specific Geographic Areas (Second Part) Transfer pricing in developing countries Joel Lachlan Cooper

Friday, May 22, 2015 Transfer Pricing Aspects of Selected Intra-Group Transactions 09.00-10.30 Transfer Pricing and Intra-Group Services Alfred Storck 11.00-12.30 Transfer Pricing, Supply Chain Management and Business Restructurings Andrea Lahodny and Alfred Storck 14.00-15.30 Transfer Pricing and Intangibles (Including Cost Contribution Arrangements) Alfred Storck and Theresa Stradinger 16.00-17.30 Transfer Pricing and Intra-Group Financing Alfred Storck and Raffaele Petruzzi

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Lecturers Lecturers are international leading transfer pricing experts from academia, international organizations, tax administrations, the business community, and tax advisory firms.

Prof. Alfred Storck (Switzerland/Austria) Professor of Transfer Pricing and International Taxation Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria)

Raffaele Petruzzi, LL.M. (Italy/Austria) Research Associate in International Taxation and Transfer Pricing Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria) Transfer Pricing Advisor Deloitte Vienna (Austria)

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Dr. Sven Bremer (Germany) Global Head of Group Transfer Pricing Siemens Munich (Germany)

Joel Lachlan Cooper, LL.M. (Australia) International Tax (Transfer Pricing) Specialist World Bank Group Belgrade (Serbia)

Dr. Giammarco Cottani, LL.M. (Italy) Advisor to the Italian Revenue Agency’s Deputy Commissioner on Transfer Pricing and International Taxation Italian Revenue Authorities Rome and Milan (Italy)

Axel Eigelshoven (Germany) Certified Tax Advisor and Transfer Pricing Partner PwC Düsseldorf (Germany)

Sebastien Gonnet (France) Vice President Global Transfer Pricing NERA Economic Consulting Paris (France)

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Judith Herdin-Winter (Austria) Deputy Head Division for International Tax Law Austrian Federal Ministry of Finance Vienna (Austria) Former Research Associate in International Taxation Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria)

Monique van Herksen (United States/the Netherlands) Global Transfer Pricing Controversy Leader EY New York (United States)

Dr. Andrea Lahodny (Austria) Transfer Pricing Country Leader Deloitte Vienna (Austria) Former Research Associate in International Taxation and Transfer Pricing Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria)

Prof. Helmut Loukota (Austria) Professor of International Taxation Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria) Former Head of the Division for International Tax Law Austrian Federal Ministry of Finance Vienna (Austria)

Marta Pankiv, LL.M. (Ukraine) Research Associate (Doctoral Program in International Business Taxation) Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria) Tax Advisor, Transfer Pricing PwC Vienna (Austria)

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Hans Pijl (the Netherlands) Of Counsel (Former Partner) on International Taxation Deloitte Amsterdam (the Netherlands) Part-Time Judge The Hague Tax Court of Appeals The Haugue (the Netherlands)

Dr. Theresa Stradinger (Austria) Certified Tax Advisor and Transfer Pricing Advisor KPMG Vienna (Austria) Former Research Associate in International Taxation and Transfer Pricing Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria)

Romero Tavares, Esq., LL.B., M.B.A. (Brazil/United States) Research Associate in International Taxation Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria) Vice-President, Supply Chain Design, Tax & Trade Flextronics International Ltd. Vienna (Austria), San Jose (California, United States) Former Head of Tax Policy & Tax Controversy; Corporate Tax Advisory EY São Paulo (Brazil) Former Head of International Tax Services Deloitte São Paulo (Brazil)

Elena Variychuk (Russia) International Tax and Transfer Pricing KPMG Vienna (Austria) Former Research Associate in International Taxation Institute for Austrian and International Tax Law Vienna University of Economics and Business (WU) Vienna (Austria)

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Lunches, Coffee Breaks, and Others The course includes, every day, two coffee breaks and one lunch. A dinner is organized for the evening of May 20, 2015. Participants can join these events free of charge.

Course Materials The participants are provided, at the beginning of the course, with a binder containing the presentations and the case studies discussed during the workshops. Additionally, a USB stick is provided, containing further documents (in electronic format), which are relevant for the course.

Course Level and Prerequisites The course starts from an introductory level. Hence, it can be attended by both participants with no experience in transfer pricing and participants with some experience in the field. No advanced preparations are required. In September 2015, a more advanced level course will be provided.

Venue The course is held in Vienna at the WU campus (www.wu.ac.at/campus/en/), which is conveniently accessible by public transportation. The address of the campus is: Vienna University of Economics and Business (Wirtschaftsuniversität Wien, WU) Welthandelsplatz 1 1020 Vienna, Austria

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WU Campus © Studio Huger

Course Fees The course fees are 1,750.- Euro. A 20% “early bird discount” is applicable to applications sent by February 28, 2015. The course fees cover course participation, all course materials, lunches, coffee breaks and refreshments. The costs of accommodation and transport are not covered.

Questions and Contact For any question regarding the attendance of the course, travel arrangements, payments, and other similar topics please contact Ms. Hedwig Pfanner ([email protected]).

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Registration Payment You will receive an invoice for the participation fee of 1,750.- Euro which we ask you to transfer to the bank account specified in the invoice (payment deadline: May 1, 2015).

Cancellation Any notification of cancellation of registration must be sent in writing to Ms. Hedwig Pfanner ([email protected]). In case of cancellation before April 18, 2015, the participation fee will be refunded. No refund can be made for cancellations received after April 18, 2015.

Application Please fill out the attached application form and submit it to Ms. Hedwig Pfanner ([email protected]).

We are looking forward to welcoming you to Vienna! M. Lang / J. Owens / P. Pistone / A. Rust / J. Schuch / C. Staringer / A. Storck / R. Petruzzi

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Application Form I hereby submit my application for the Global Transfer Pricing Course held from May 18 to May 22, 2015 in Vienna (Austria).

Please write clearly using block letters. All fields marked with * are required.

First name* Surname* Academic Title (e.g. BA, MA, LL.M., Dr.) Gender

male

female

Nationality* Current position and company / organisation*

Private details Street Zip-Code, City Country Phone / Mobile* (for very urgent issues) E-Mail*

Billing address Please indicate the exact name and address to be shown on the invoice Name / company* Street* Zip-Code, City* Country*

Date, Signature

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