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08:30 - 08:55 25 mins
Registration & Coffee
08:55 - 09:00 5 mins
Chair's Opening Remarks
  • Brian Cody - Principal, Global Transfer Pricing Services, KPMG
09:00 - 09:30 30 mins
Keynote Speech - Latest Thinking on State Aid by the European Commission
  • Karl Soukup - Director, Directorate General for Competition, EUROPEAN COMMISSION
  • Understanding the Instrument of State Aid Control in Europe
  • Discussion of recent State Aid cases
  • What can US multinationals learn from the Commission decisions
  • Other relevant developments at EC level
09:30 - 10:25 55 mins
The Future of Global Transfer Pricing Policy
  • Norman Wingen - Tax Adviser - MAP, OECD
  • Michael Lennard - Chief, International Tax Cooperation; Financing for Development Office, UNITED NATIONS
  • Karl Soukup - Director, Directorate General for Competition, EUROPEAN COMMISSION
  • Carlos Pérez-Gomez - SAT (Servicio de Administración Tributaria), Transfer Pricing, MEXICAN TAX ADMINISTRATION
  • Moderator: Matthew Frank - Principal, Global Transfer Pricing Services, KPMG

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:

  • Where the action is: Will domestic transfer pricing policy be driven domestically or by multilateral bodies, and is multilateral transfer pricing policy effective – does it impose meaningful constraints on domestic transfer pricing administration?
  • Multilateral transfer pricing policy – is there coordination/consensus among OECD/UN/EC?
  • Will global transfer pricing policy diminish in importance due to domestic carve-outs and non-TP measures?
  • Transfer pricing dispute resolution: Will new mechanisms and policies be developed and broadly applied? Will goals and expectations change?
  • Priorities for the future of global transfer pricing policy
10:25 - 10:45 20 mins
Coffee Break
10:45 - 11:25 40 mins
Managing Risk & Dealing With Uncertainty
  • Maximo Spinedi - Regional Head of Tax, Argentina, SIEMENS
  • Mario Agnese - International Tax Senior Manager, BP
  • Keith Brockman - VP Global Tax, WELBILT
  • Katherine Amos - Global Head of Transfer Pricing, JOHNSON & JOHNSON
  • Moderator: Susan Fickling-Munge - Managing Director, DUFF & PHELPS

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.

11:25 - 12:05 40 mins
Country by Country Reporting - Tales from the Trenches
  • Brad Parker - Senior Transfer Pricing Manager, INTEL CORPORATION
  • Kim Mancini - Senior Manager, GM Transfer Pricing, GENERAL MOTORS
  • Sam Barrett - Head of International Tax & Global Transfer Pricing, SANDVIK
  • Nicole Williams - Senior Manager, Global Transfer Pricing, CELANESE
  • Karen Milhoua - Vice President - Transfer Pricing, NEWELL BRANDS
  • Moderator: Kim Majure - Principal, International Tax, KPMG

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:

  • “The Plan” with respect to your CbyC report data and foreign government risk assessment
  • Practical recommendations and best practices with respect to US and foreign CbyC reporting
  • OECD and EU transparency developments – tax and “tax-esque” exposures for multinational enterprises
12:05 - 12:45 40 mins
Taxing the Digital Economy - What Will the New OECD Focus on Digital Economy Taxation Mean for your Industry?
  • Liz Chien - Global Tax Director, GE DIGITAL
  • Eduardo Goldszal - Head of Transfer Pricing, NCR CORPORATION
  • Debora Correa Talutto - Group Transfer Pricing Manager & Senior NSA Tax Manager, TEMENOS
  • Moderator: Vladimir Starkov - Associate Director, NERA ECONOMIC CONSULTING

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.

12:45 - 13:55 70 mins
13:55 - 14:15 20 mins
Latest Developments at IRS Level
  • John Hughes - Director, APMA, IRS

Session to be delivered via live video link from Washington D.C.

14:15 - 14:55 40 mins
The APA Landscape: How APAs Are Affected by "Eaton" and U.S. Tax Reform
  • Mike Manuel - Director - TI Global Tax Provision & Transfer Pricing, TEXAS INSTRUMENTS
  • Peter De Nicola - Director of Taxes, FUJIFILM
  • Joan Hortalà Vallvé - Partner, CUATRECASAS
  • Graeme Wood - Head of Global Transfer Pricing, PROCTER & GAMBLE
  • Moderator: Clark Armitage - Member, CAPLIN & DRYSDALE

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:

  • Whether the IRS may enforce an APA against the APA taxpayer
  • The burden of proof in cases involving an attempted rescission of an APA
  • Whether taxpayers’ obligations to provide an accurate and complete submission have changed; and
  • How to handle compliance issues in the APA Annual Report process.
14:55 - 15:35 40 mins
Permanent Establishments and Attribution of Profits
  • Mario Agnese - International Tax Senior Manager, BP
  • Walter Kolligs - Vice President - Head of International Tax, VISA
  • Richard Goldberg - Americas Transfer Pricing Manager, MITSUBISHI UFJ FINANCIAL GROUP
  • Moderator: David Forst - Partner, FENWICK & WEST

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.

15:35 - 16:15 40 mins
Making Cost Sharing Work Post-BEPS
  • Justin Smith - Managing Director, TRUE PARTNERS CONSULTING

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:

  • Overview of how the landscape for CSAs has changed since BEPS
  • Practical guidance on how Development, Enhancement, Maintenance, Protection and Exploitation functions should integrate with the tax structure and the CSA itself
  • Changes to valuation concepts surrounding platform contributions to CSAs
  • Predicting the expected financial outcomes of the CSA and the expected returns for Cost Sharing participants
  • Managing a constantly changing exploitation environment as the CSA matures
16:15 - 16:30 15 mins
Coffee Break
16:30 - 17:10 40 mins
Operational Transfer Pricing
  • Doreen Liu - Managing Director, Global Transfer Pricing Services, KPMG
  • Chris Schulman - Senior Manager, Tax Ignition, Tax Data & Analytics, KPMG

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:

  • Overview of challenges, such as data management, cross-functional process integration, communication and accountability
  • Leading practices regarding technology enablement and tools for automation, real-time monitoring, and enhanced accuracy and efficiency
  • Integration and collaboration across functional areas such as tax, finance and accounting, treasury, operations, and IT
  • Increasing focus of tax authorities on data quality and ability to reconcile/substantiate segmented financials used in transfer pricing studies
  • Practical approach to assessing, designing, and implementing leading operational transfer pricing practices within your organization
17:10 - 17:45 35 mins
Transfer Pricing Technology: How to Define, Defend and Build Consensus for an Automation Project
  • Sam Cicogna - VP & Head ONESOURCE Transfer Pricing, THOMSON REUTERS
  • Janet Tarver - Director of International Tax (Transfer Pricing), FEDEX

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.

17:45 - 19:45 120 mins
Close of Day 1 & Drinks Reception