Global Transfer Pricing Forum

CLE/C PD accred ited 10 HOUR S 12th Annual Global Transfer Pricing Forum September 24-25, 2012 The Westin, Paris Why attend? • Speak directly with...
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CLE/C PD accred ited

10

HOUR S

12th Annual

Global Transfer Pricing Forum September 24-25, 2012 The Westin, Paris Why attend? • Speak directly with revenue officials • Hear updates about the OECD's Working Party 6 project on transfer pricing aspects of intangibles • Participate in panel debates on: transfer pricing controversies in India and China; management fees; practical issues in using branches versus corporate subsidiaries for structuring international businesses; and APAs in dispute resolution • Inform yourself with the right methods for dealing with audits • Keep up with developments at multilateral organisations • Gain 10 CLE/CPD points

In association with

www.internationaltaxreview.com/TPForum2012

Global Transfer Pricing Forum 2012

12th Annual Global Transfer Pricing Forum September 24-25, 2012 The Westin, Paris The 12th annual Global Transfer Pricing Forum will give delegates an opportunity to speak directly with revenue officials, hear from the OECD and other global organisations and participate in panel debates, as well as listen to pertinent keynote speeches. This year’s event will be enhanced by the involvement of leading tax and transfer pricing executives, and current and former administrators, such as Caroline Silberztein, ex-senior member of the OECD’s Centre for Tax Policy and Administration, and now partner of Baker & McKenzie, Peter Steeds, deputy director and Head of TP, Business International, at HM Revenue & Customs and Michelle Levac, transfer pricing specialist at Canada Revenue Authority and chair of OECD WP6. With a variety of representatives of some of the world’s biggest multinational taxpayers in attendance, the International Tax Review and TPWeek Global Transfer Pricing Forum 2012 promises to be a valuable experience and source of new insights.

Who should attend: • •

Corporate tax directors • Corporate transfer pricing managers •

Revenue officials Private practitioners

• •

Finance directors Transfer pricing economists

Join the Global Transfer Pricing Forum 2012 group on LinkedIn for the latest news about the conference: http://www.linkedin.com/groups?gid=3194275&trk=hb_side_g

The Westin Paris Vendôme The Westin Paris Vendôme is located in the city’s first arrondissement, making it easy for guests to combine business and pleasure. Discover the perfect balance between traditional Parisian influence and contemporary design in one of the 428 rooms and Suites and enjoy some downtime but also a breathtaking view from the Louvre to the Eiffel Tower. Each of our 80 suites has its own unique design and allows for the utmost in relaxation, work or entertainment. Hotel address 3 rue de Castiglione • 75001 Paris · France www.thewestinparis.com Reduced room rates are available for forum delegates on September 23 & 24 2012: €370/night for a Superior Single Room and €395/night for a Superior Double Room (taxes and breakfast buffet included). To reserve your room please complete this form: www.internationaltaxreview.com/pdfs/WestinBookingForm.pdf and email to [email protected]

Visit: www.internationaltaxreview.com/TPForum2012 Call: + 44 (0) 020 7779 7222 Email: [email protected] Twitter: #TPweek

Global Transfer Pricing Forum 2012

International Tax Review

GLOBAL TRANSFER PRICING FORUM 2012 September 24-25, 2012 • The Westin, Paris DAY 1 MONDAY SEPTEMBER 24 8:30 9:00

Registration and breakfast

2:00

Opening remarks



How should management fees be charged in the BRIC countries? Myth and reality • What are the real issues in France, the US, China, India and elsewhere? • What are the most scrutinised service fees? Marc Levey, Partner, Baker & McKenzie, US (moderator) Catherine Damelincourt, Tax Director, Alstom, France François Gadel, Senior Vice President, Tax, LVMH, France Margreet Nijhof, Partner, Baker & McKenzie, Netherlands Ruslan Vasutin, Partner, DLA Piper, Russia Jitendra Jain, Vice President, Transfer pricing, General Electric, India

Ralph Cunningham, Managing Editor, International Tax Review

9:10

Keynote Address

9:30

Transfer pricing developments: trends and challenges ahead • •

The future of the arm’s-length principle The roles of the OECD and of the UN and the increasing importance of new voices from emerging countries and non-governmental organisations • Challenges ahead for intangible migrations, compliance and enforcement • Global trends in transfer pricing policy Caroline Silberztein, Partner, Baker & McKenzie, France (moderator) Cyrille Dero, Deputy Tax Director, LVMH, France Michelle Levac, Transfer Pricing Specialist, International Tax Division, Canada Revenue Authority and Chair, OECD Working Party No 6, Canada Marlies De Ruiter, Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division, OECD, France Gregg Lemein, Partner, Baker & McKenzie, US John Neighbour, Partner,

3:15

Tea and coffee

3:45

The search for tax certainty – are current APA programmes sufficient? The number of jurisdictions that offer an advance pricing agreement programme is increasing, and it appears that the trend will only continue. This reflects the fact that it is in the interests of both tax authorities and taxpayers that they obtain certainty over major transfer pricing issues at an early stage, reducing future potentially costly dispute resolution for both parties and allowing resources to be reallocated accordingly. However, with cross-border intragroup relationships only multiplying, and technical issues becoming more complex leading to increasingly diversifying views, can the current APA programmes meet the needs? • What tax authorities are doing, might do and should consider doing to continue to enhance the search for tax certainty in the APA arena • How taxpayers can contribute to this process Richard Fletcher, Principal Economist, Baker & McKenzie, UK (moderator) Sarah Fahy, Vice President - Global Tax Office Europe, Sony Corporate Services Europe, UK Eric Lesprit, Head of French APA Team, French Tax Administration, France François Vincent, Leader Global Transfer Pricing Dispute Resolution, , France Ken Okawara, Principal Economist, Baker & McKenzie, Japan

, UK

10:45

Tea and coffee

11:15

Emerging economy perspectives Emerging transfer pricing controversies and dispute resolution options in China, India, South Africa, and other emerging economies: • Locational advantages • Market premia • “Economic” ownership • Embedded intangibles Carol Dunahoo, Partner, Baker & McKenzie, US (moderator) Nishana Gosai, Manager, Transfer Pricing, Large Business Centre, South African Revenue Service, South Africa Rahul Mitra, National Leader Transfer Pricing Practice, , India Glenn DeSouza, China Transfer Pricing Leader, Baker & McKenzie, China Lesley Holstead, Tax Executive- Risk Strategy, Vodafone Group Services, UK

12:30

Management fees: between a rock and a hard place

Lunch with keynote speaker Cym Lowell, Vice Chairman, Taxation Commission, International Chamber of Commerce

5:00

Chairman’s closing remarks

5:15

Cocktail reception

Visit: www.internationaltaxreview.com/TPForum2012 Call: + 44 (0) 020 7779 7222 Email: [email protected] Twitter: #TPweek

International Tax Review

GLOBAL TRANSFER PRICING FORUM 2012 September 24-25, 2012 • The Westin, Paris DAY 2 TUESDAY SEPTEMBER 25 8:30 9:00

Registration and breakfast

1:30

Opening remarks

• •

Officials’ view of how documentation rules are working Whether legal certainty in transfer pricing matter can be enhanced • Whether advance pricing agreements operate effectively in this respect • The future for joint audits; litigation vs settlement • Alternative dispute resolution Len Terr, Partner, Baker & McKenzie, US (moderator) Eric Lesprit, Head of French APA team, French Tax Administration, France Michelle Levac, Transfer Pricing Specialist, International Tax Division, Canada Revenue Authority and Chair, OECD Working Party No 6, Canada Peter Steeds, Deputy Director and Head of TP, Business International, HM Revenue & Customs, UK Nishana Gosai, Manager, Transfer Pricing, Large Business Centre, South African Revenue Service, South Africa

Sophie Ashley, Managing Editor, TPWeek

9:15

Intangibles: the latest developments Overview of the contents of the OECD discussion draft on intangibles • Case studies illustrating how the new guidance may affect multinational enterprises’ transfer pricing models and planning Caroline Silberztein, Partner, Baker & McKenzie, France (moderator) Joseph Andrus, Head of the Transfer Pricing Unit, OECD, France Philippe Paumier, Head of Transfer Pricing, SanofiAventis, France Peter Steeds, Deputy Director and Head of TP, Business International, HM Revenue & Customs, UK Holly Glenn, Principal Economist, Baker & McKenzie, US Ronald van den Brekel, Partner, , Netherlands



10:45

Tea and coffee

11:15

Dispute Resolution: global approaches to global issues

2:45

Tea and coffee

3:15

Practical differences in using branches vs. corporate subsidiaries for structuring international businesses • • • •

Profit repatriation Loss utilisation Tax credit impacts Profit allocation on the basis of concrete transactions such as deliveries of goods, usage of intangibles, and finance Pierre-Yves Bourtourault, Partner, Baker & McKenzie, France (moderator) Napoleão Dagnese, Head of International Tax, Deputy Head of Group Tax, OC Oerlikon Management, Switzerland Inga Kondrataite, Senior Manager, Transfer Pricing, Nissan Europe, France Sam Sim, Head of Wholesale Transfer Pricing, Standard Chartered Bank, Singapore Stephan Schnorberger, Partner, Baker & McKenzie, Germany



Hot transfer pricing topics that are the subject of disputes in key jurisdictions • Options for successfully resolving such disputes • Best practices for proactively addressing transfer pricing issues • Preparing for disputes before they arise Salim Rahim, Partner, Baker & McKenzie, US (moderator) Brad Rolph, Vice President, , Canada Matt Frank, Senior Tax Counsel, Transfer Pricing, General Electric, US Giuliana Polacco, Partner, Baker & McKenzie, Italy 12:30

Ask the tax authorities (Interactive Q&A session)

Lunch 4:30

Chairman’s closing remarks

4:45

End of conference

Exhibitors

Visit: www.internationaltaxreview.com/TPForum2012 Call: + 44 (0) 020 7779 7222 Email: [email protected] Twitter: #TPweek

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