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How are the international organizations such as the United Nations, European Commssion, OECD and Tax Administrations addressing transfer pricing, both the latest BEPS developments, and where they expect transfer pricing to develop in the future? This panel will examine:
In-house professionals come together to share their insights into how best to navigate the present international tax landscape, with specific reference to: managing international tax risks such as attribution of profits to Permanent Establishments, EU State Aid, reputational risk, and other emerging areas of concern. Panellists will also explore and debate strategies for dealing with uncertainty in light of on-going tax reform drives both globally and domestically.
Now that the first wave of Country by Country (CbyC) Reporting is behind us, US filers are asking “what’s next?” How is the data going to be used – and will it be abused? And how are US multinational groups supposed to address the rapidly evolving Action 13 guidance in other countries? What are the prospects and implications of EU “public” CbyC Reporting? During this session, we will discuss:
Digital economy taxation remains at the centre of OECD’s BEPS action plan with further developments expected for Action 1 by early next year. This panel will assemble in-house transfer pricing experts at the forefront of the so called digital economy to discuss what latest policy developments will mean for their business and what can be done to help shape policy in this area.
Session to be delivered via live video link from Washington D.C.
The panel will address how the Tax Court’s Eaton decision affects the enforceability of APAs, as well as its impact on preparing submissions and compliance. The panel will discuss:
Attribution of Profits to Permanent Establishments will continue to be a major issue for corporates in 2017 and beyond. This panel will analyse why the OECD is looking at attribution of profits and whether there will be a further increase in the compliance burden for multinationals. Panellists will also discuss Dependent Agent PEs and the complexity surrounding the “Authorised OECD Approach” (AOA) to attributing profits.
In 2015 the OECD issued its final report on transfer pricing under Actions 8-10 of its Action Plan on Base Erosion and Profit Shifting. The report focused heavily on special considerations for intangible assets, and provided specific guidance on Cost Sharing Arrangements. CSAs have long been a practical tool for sharing in the development and exploitation of intangibles across an organization. They have also frequently been abused as tax planning tools, trapping income in low tax jurisdictions. Since the BEPS report, taxing authorities have taken a more stringent view of CSAs, but this has not eliminated their use or usefulness. This presentation will focus on:
Multinational companies spend significant time and effort designing transfer pricing policies that meet strategic objectives and regulatory requirements. However, when the implementation of these policies falls short, companies are exposed to misstated financial statements, increased tax liabilities, and penalties. Effective integration of transfer pricing policies with accounting and operations can provide significant benefits in terms of efficiency, risk mitigation, and accounting integrity. This session will examine:
Transfer Pricing practitioners have been doing more with less for quite some time now. The advent of BEPS has created the need to gather, analyze and understand data and other processes across functional areas within the company. As transfer pricing reporting requirements impact these areas and the need to collaborate with these teams, “doing more with less” no longer only impacts the transfer pricing function and is creating an ideal environment to adopt technology for the benefit of everyone. However, in order to adopt technology, you first need to acquire funding and provide KPI’s to prove success in the investment. This session will explore some key strategies for building a case for technology, experiences of what stakeholders are looking for and real life experiences that participants can utilize in their own thought processes when looking to expand their technology footprint.