IIR & IBC Finance is part of the Knowledge and Networking Division of Informa PLC

This site is operated by a business or businesses owned by Informa PLC and all copyright resides with them. Informa PLC's registered office is 5 Howick Place, London SW1P 1WG. Registered in England and Wales. Number 3099067.

Informa
08:00 - 08:45 45 mins
Info
BREAKFAST BRIEFING (Day 1) - Transfer Pricing Perspectives - US, UK, Australia and Germany
  • Paul Daly - Transfer Pricing Partner, BDO
  • Zara Richie - Head of Global Transfer Pricing Services , BDO
  • Mark Shuette - National Transfer Pricing Leader, BDO
  • Dirk Elbert - Head of International Tax Services, BDO

This session will cover updates from some of the key transfer pricing territories and contain a local perspective on how the changes from the OECD are being effected in local law and practice. The session will be a discussion based panel examining the current status of transfer pricing compliance and controversy in territory, predicted trends, and how multinationals can prepare for increased challenge. Senior transfer pricing leaders will cover developments in the United States, United Kingdom, Australia and Germany, including the evolving approaches of the respective tax authorities and what they expect in 2019 and beyond. This discussion based session includes:

  • Updates from key transfer pricing territories
  • Overview of key TP Developments in Europe (UK/Germany), Americas (US) and Asia-Pacific (Australia)
  • Discussion of current compliance and controversy trends
  • Examining what's to come in 2019 and beyond
08:45 - 09:00 15 mins
Registration & Coffee
09:00 - 09:10 10 mins
Chair's Opening Remarks
  • Ruth Steedman - Senior Managing Director, FTI CONSULTING
09:10 - 09:30 20 mins
Info
Keynote Speech

OECD Under Invitation

09:30 - 10:05 35 mins
Info
An Insider Look Into How Tax Tax Policy Works in Practice
  • Jens Svolgaard - Vice President Tax, SPOTIFY

As the international tax landscape continues to go through a period of profound transformation and likely a global reform, Jens Svolgaard, takes us through a journey of understanding as to how tax policy is developed and take shape in practice, and how the political and tax technical worlds coalesce to create the standards to be observed by multinational companies worldwide. This high level presentation is another unmissable session in our 2019 agenda and sure to be one of the talking points at next year’s event. Not to be missed.

10:05 - 10:50 45 mins
TP2020 - Current State of Play and Policy Maker's Outlook
  • Michael Lennard - Chief, International Tax Cooperation; Financing for Development Office, UNITED NATIONS
  • Cory Hillier - Counsel Tax Law, IMF
  • Mauro Faggion - Policy Officer, EUROPEAN COMMISSION
  • Andrew Page - Deputy Director, HMRC
  • Luximan Babajee - Senior Technical Officer; Tariff and Trade Affairs Directorate (Valuation), WCO
10:50 - 11:10 20 mins
Morning Coffee Break
11:10 - 11:50 40 mins
Info
The Role of the Arm’s Length Principle Post BEPS
  • Catherine Harlow - Head of Transfer Pricing, ASTRAZENECA
  • Giacomo Soldani - Head of Tax, LUXOTTICA
  • Matt Hardy - Tax Director of Transfer Pricing & Indirect Taxes, DIAGEO
  • Filippo Baldi - Associate Director Global Transfer Pricing, TAKEDA PHARMACEUTICALS
  • Moderator: Anton Hume - Tax Partner, Corporate International Tax, BDO

In-house transfer pricing leaders will come together to take the pulse to where we are in relation to the future of the Arm’s Length Principle. This session will cover the role of the arm’s length principle in the current international tax environment post BEPS, and examine some of the interactions that are growing more pronounced with other areas of international taxation. In addition to exploring some of the overlaps we will consider the question as to how our approach as transfer pricing practitioners flexes in response. Aspects that will be explored by the panel will include the role of the arm’s length principle in diverted profits tax, financing arrangements and corporate interest restriction, the impact of CbCR data, the interaction and tension with indirect taxes, the relationship with permanent establishment, employment tax issues and digital services tax.

11:50 - 12:35 45 mins
Info
Taxing the Digital Economy - Are Users' The New Battle Ground?
  • Liz Chien - VP of Global Tax, RIPPLE LABS
  • Sam Barrett - Global Head of Tax, IFLIX
  • Elias Thomas - Senior Manager - Transfer Pricing, SPOTIFY
  • Jesús Bravo Fernández - Director - Tax Strategy, External Communications & Transfer Pricing, COCA COLA
  • Moderator: Kirsty Rockall - Director, KPMG

Taxation of the Digital Economy remains at the top of policy makers’ agendas worldwide, with the OECD, EU, as well as different Tax Administrations taking action. What does this have to do with transfer pricing? How do we assess value in digitally enabled business models? Are we simply going to end up with a myriad of additional consumption taxes? These questions and more will be answered by our panel of in-house transfer pricing experts. The panel will also discuss what the latest policy developments mean for their business, and how industry is responding, which will bring a practical element to the debate.

12:35 - 13:05 30 mins
Info
A Detailed Look at Financial Transactions
  • Lukasz Kubicki - Head of International Tax, OERLIKON

This thought leadership presentation will very briefly summarize the status of OECD's work on transfer pricing aspects of financial transactions and proceed to outline the practical consequences of recent developments to the day-to-day tax function. Lastly, the presenter would share his views and insights on long term adaptation needs to the new regulations. The main areas of coverage include:

  • Status of OECD work vs. other initiatives on this subject
  • Overlap of work on financial transactions with other aspects of BEPS
  • Practical insights into day-to-day interaction of tax and treasury functions
  • Assessment on potential changes to the tax landscape
13:05 - 14:15 70 mins
Info
Lunch

Conference Luncheon sponsored by S&P Global Market Intelligence

14:15 - 14:55 40 mins
Info
Financing, Cash Pooling and Captive Insurance - A Step Too Far by the OECD?
  • Louise Sykes - SVP, Head of Transfer Pricing, AXA
  • Andrea Lee - Head of Group Project and Group Cost Controlling and TP, ERSTE GROUP
  • Catherine Clare - Group Tax Projects Manager, INFORMA
  • Kerim Keser - Managing Director, Transfer Pricing, DUFF & PHELPS

Financial Transactions have been in the spotlight since the OECD release of its discussion draft in this important area in June 2018. The pricing of debt is something that will affect all companies and not just financial groups. This panel session will discuss the different principles used to calculate the amount of debt, cash pooling and captive insurance and explore whether this is a step too far by the OECD.

14:55 - 15:35 40 mins
Info
MAP, BAPAs and the Quest for Single Taxation
  • Arnaud Sage - Head of the APA & MAP Department (MEJEI), FRENCH COMPETENT AUTHORITY
  • Barbara Dooley - Principal Officer, Transfer Pricing Policy, IRISH REVENUE
  • Dominic Vines - Team Leader (Financial TP); Delegated Competent Authority, HMRC
  • Moderator: Joel Cooper - Co-Head International Transfer Pricing Group, DLA PIPER

This panel explores the current evolving landscape of both MAP and bilateral APAs from the perspective of government - via representatives from the competent authorities themselves - as well as business. MAP in particular is examined in light of new OECD statistics, various other forces that are impacting case closure statistics, and the importance the function has for MNCs from an international taxation perspective. Speakers will explore:

  • Trends in APAs and MAPs
  • Best practices in a changing tax world
  • Impact of MLI, inclusive framework etc
  • What is the role of MAP in the future
15:35 - 16:10 35 mins
Info
Ask the Experts Q&A Session
  • Kari Pahlman - Vice President, Global Tax and Treasury, TECHTRONICS INDUSTRIES
  • John Neighbour - Independent Transfer Pricing Consultant, INDEPENDENT

This session explores real-time audience questions and input in an interactive fashion. As conference sessions do not always have sufficient time to address the numerous interesting and divergent audience questions, this panel is dedicated to addressing this unmet need. In this session, experienced experts will select and discuss audience originated transfer pricing and tax topics, with a view of expanding the dialogue beyond the conventional approaches of a given topic. Active audience input/participation is a precondition for this session.

16:10 - 16:30 20 mins
Coffee Break
16:30 - 17:10 40 mins
Info
Stream A
Dealing with PE Risk and Profit Attribution
  • Jean-Louis Barsac - Group Transfer Pricing and Regional Tax Leader, NOKIA
  • Gabriella Cappelleri - Of Counsel, MAISTO

There is currently a heightened focus on PE thresholds by tax administrations globally, with a patchwork of divergent approaches, as each country begins to adopt its own unique tax base defence response to Action 7. Whether following approaches set out in the MLI, or by taking unilateral domestic action, tax administrations are increasingly ready and equipped to challenge PE status. This session will survey the recent international developments in this space, explain key indicators of PE and Profit Attribution risk, and provide practical steps that multinationals can be take in order to mitigate risk, defend positions, and ensure robustness of their global ETR strategy.

16:30 - 17:10 40 mins
Info
Stream B
CbCR Enquiries - Current Experiences and Outlook for 2020
  • Catherine Harlow - Head of Transfer Pricing, ASTRAZENECA
  • Luis Abrantes - Head of Transfer Pricing, CARLSBERG
  • Lukasz Kubicki - Head of International Tax, OERLIKON
  • Luis Carrillo - Transfer Pricing Director, BUREAU VAN DIJK

Automatic Exchange of Information on CbCR started in mid-2018 and it is therefore likely that by March 2019 the first enquiries from tax administrations will have started to emerge. Are we seeing more audits and enquiries as a result of CbCR submissions? This panel will assemble both tax administrations and in-house transfer pricing professionals to discuss current experiences and also look into potential changes to the CbCR template, which is due to be revised in 2020.

16:30 - 17:10 40 mins
Stream C
Operational Transfer Pricing
  • Monica Erasmus-Koen - Managing Partner Transfer Pricing, TAXTIMBRE
16:30 - 17:50 80 mins
Info
Stream D
Working Groups
  • Facilitator - Digital Economy: Amanda Pletz - Associate Director, NERA ECONOMIC CONSULTING
  • Facilitator - Financial Transactions: Raffaello Fossati - Head of Transfer Pricing, FANTOZZI & ASSOCIATI

Working Group 1 - Financial Transactions Within Groups

Working Group 2 - Taxation of the Digital Economy

Working Group 3 - Valuation of IP

Working Group 4 - CbCR: Towards at 2020 Vision

17:10 - 17:50 40 mins
Info
Stream A
Countdown to Brexit - What Next for Supply Chains and TP
  • Don Shackley - Head of Transfer Pricing, BURBERRY
  • Glyn Fullelove - President, CIOT
  • Denise Valin Alvarez - Director, Global Trade Compliance, BURBERRY
  • Lluís Fargas - Vice President Tax, Controller & Corporate Development Europe, ARCONIC

TP Minds will take place 9 days before Brexit day. The countdown has well and truly begun but there is little certainty about the manner of the UK’s exit from the European Union and what this is going to mean in practical terms. This session will explore the tax implications of Brexit on supply chains and discuss what businesses should be doing now to meet the new challenges to their current arrangements. It will also consider that how all our TP guidelines and assumptions have been developed for a world where trade has been becoming more and more free; what does greater protectionism and the reshaping of free trade agreements and areas mean for TP?

17:10 - 17:50 40 mins
Info
Stream B
TP & The U.S. Tax Landscape - One Year After Tax Cuts and Jobs Act
  • Katherine Amos - Global Head of Transfer Pricing, JOHNSON & JOHNSON
  • Louisa Gonzalez - VP of Tax, CONVATEC
  • Moderator: Elizabeth Stevens - Associate, CAPLIN & DRYSDALE

Our expert speaker faculty will explore how multinationals are navigating the Tax Cuts and Jobs Act, examine international implications for Cross-Border Business, recommend approaches to Tax Controversy under U.S. Tax Reform and much more besides. Panellists will also share strategic guidance on approaches to key areas of the TCJA such as BEAT, GILTI and FDII as well as tips on how to successfully navigate uncertainties.

17:10 - 17:50 40 mins
Info
Stream C
Tax Transformation & Technology - Setting Your Vision for the Future of the Tax Department
  • Mark Houtzager - EMEA Tax Leader, STARBUCKS
  • Yvonne Schindele - Senior Manager Transfer Pricing (Vice President), SWISS RE
  • Arnis Lībenzons - Head of E-Commerce Team, TAX CONTROL BOARD LATVIA
  • Fabio De Angelis - Head of International Tax, PHILIP MORRIS INTERNATIONAL
  • Moderator: Matthew Whipp - Partner; IMG and B2C Lead, Global Transfer Pricing Services, KPMG

This industry panel comes together to discuss tax transformation and the digitalization of tax processes from a tax payers’ perspective. Areas under examination include: Dealing with increased burden of tax administration on tax departments; Increasing transparency and improving efficiency of tax operations; Designing and defending a successful tax technology strategy; Data issues in improving the consistency of compliance processes; Automation and streamlining of tax processes, and much more besides.

17:50 - 19:50 120 mins
Closing Remarks & Drink Reception
08:00 - 08:45
Info

BREAKFAST BRIEFING (Day 1) - Transfer Pricing Perspectives - US, UK, Australia and Germany

This session will cover updates from some of the key transfer pricing territories and contain a local perspective on how the changes from the OECD are being effected in local law and practice. The session will be a discussion based panel examining the current status of transfer pricing compliance and controversy in territory, predicted trends, and how multinationals can prepare for increased challenge. Senior transfer pricing leaders will cover developments in the United States, United Kingdom, Australia and Germany, including the evolving approaches of the respective tax authorities and what they expect in 2019 and beyond. This discussion based session includes:

  • Updates from key transfer pricing territories
  • Overview of key TP Developments in Europe (UK/Germany), Americas (US) and Asia-Pacific (Australia)
  • Discussion of current compliance and controversy trends
  • Examining what's to come in 2019 and beyond
  • Paul Daly - Transfer Pricing Partner, BDO
  • Zara Richie - Head of Global Transfer Pricing Services , BDO
  • Mark Shuette - National Transfer Pricing Leader, BDO
  • Dirk Elbert - Head of International Tax Services, BDO
More
08:45 - 09:00

Registration & Coffee

More
09:00 - 09:10
Info

Chair's Opening Remarks

  • Ruth Steedman - Senior Managing Director, FTI CONSULTING
More
09:10 - 09:30
Info

Keynote Speech

OECD Under Invitation

More
09:30 - 10:05
Info

An Insider Look Into How Tax Tax Policy Works in Practice

As the international tax landscape continues to go through a period of profound transformation and likely a global reform, Jens Svolgaard, takes us through a journey of understanding as to how tax policy is developed and take shape in practice, and how the political and tax technical worlds coalesce to create the standards to be observed by multinational companies worldwide. This high level presentation is another unmissable session in our 2019 agenda and sure to be one of the talking points at next year’s event. Not to be missed.

  • Jens Svolgaard - Vice President Tax, SPOTIFY
More
10:05 - 10:50
Info

TP2020 - Current State of Play and Policy Maker's Outlook

  • Michael Lennard - Chief, International Tax Cooperation; Financing for Development Office, UNITED NATIONS
  • Cory Hillier - Counsel Tax Law, IMF
  • Mauro Faggion - Policy Officer, EUROPEAN COMMISSION
  • Andrew Page - Deputy Director, HMRC
  • Luximan Babajee - Senior Technical Officer; Tariff and Trade Affairs Directorate (Valuation), WCO
More
10:50 - 11:10

Morning Coffee Break

More
11:10 - 11:50
Info

The Role of the Arm’s Length Principle Post BEPS

In-house transfer pricing leaders will come together to take the pulse to where we are in relation to the future of the Arm’s Length Principle. This session will cover the role of the arm’s length principle in the current international tax environment post BEPS, and examine some of the interactions that are growing more pronounced with other areas of international taxation. In addition to exploring some of the overlaps we will consider the question as to how our approach as transfer pricing practitioners flexes in response. Aspects that will be explored by the panel will include the role of the arm’s length principle in diverted profits tax, financing arrangements and corporate interest restriction, the impact of CbCR data, the interaction and tension with indirect taxes, the relationship with permanent establishment, employment tax issues and digital services tax.

  • Catherine Harlow - Head of Transfer Pricing, ASTRAZENECA
  • Giacomo Soldani - Head of Tax, LUXOTTICA
  • Matt Hardy - Tax Director of Transfer Pricing & Indirect Taxes, DIAGEO
  • Filippo Baldi - Associate Director Global Transfer Pricing, TAKEDA PHARMACEUTICALS
  • Moderator: Anton Hume - Tax Partner, Corporate International Tax, BDO
More
11:50 - 12:35
Info

Taxing the Digital Economy - Are Users' The New Battle Ground?

Taxation of the Digital Economy remains at the top of policy makers’ agendas worldwide, with the OECD, EU, as well as different Tax Administrations taking action. What does this have to do with transfer pricing? How do we assess value in digitally enabled business models? Are we simply going to end up with a myriad of additional consumption taxes? These questions and more will be answered by our panel of in-house transfer pricing experts. The panel will also discuss what the latest policy developments mean for their business, and how industry is responding, which will bring a practical element to the debate.

  • Liz Chien - VP of Global Tax, RIPPLE LABS
  • Sam Barrett - Global Head of Tax, IFLIX
  • Elias Thomas - Senior Manager - Transfer Pricing, SPOTIFY
  • Jesús Bravo Fernández - Director - Tax Strategy, External Communications & Transfer Pricing, COCA COLA
  • Moderator: Kirsty Rockall - Director, KPMG
More
12:35 - 13:05
Info

A Detailed Look at Financial Transactions

This thought leadership presentation will very briefly summarize the status of OECD's work on transfer pricing aspects of financial transactions and proceed to outline the practical consequences of recent developments to the day-to-day tax function. Lastly, the presenter would share his views and insights on long term adaptation needs to the new regulations. The main areas of coverage include:

  • Status of OECD work vs. other initiatives on this subject
  • Overlap of work on financial transactions with other aspects of BEPS
  • Practical insights into day-to-day interaction of tax and treasury functions
  • Assessment on potential changes to the tax landscape
  • Lukasz Kubicki - Head of International Tax, OERLIKON
More
13:05 - 14:15
Info

Lunch

Conference Luncheon sponsored by S&P Global Market Intelligence

More
14:15 - 14:55
Info

Financing, Cash Pooling and Captive Insurance - A Step Too Far by the OECD?

Financial Transactions have been in the spotlight since the OECD release of its discussion draft in this important area in June 2018. The pricing of debt is something that will affect all companies and not just financial groups. This panel session will discuss the different principles used to calculate the amount of debt, cash pooling and captive insurance and explore whether this is a step too far by the OECD.

  • Louise Sykes - SVP, Head of Transfer Pricing, AXA
  • Andrea Lee - Head of Group Project and Group Cost Controlling and TP, ERSTE GROUP
  • Catherine Clare - Group Tax Projects Manager, INFORMA
  • Kerim Keser - Managing Director, Transfer Pricing, DUFF & PHELPS
More
14:55 - 15:35
Info

MAP, BAPAs and the Quest for Single Taxation

This panel explores the current evolving landscape of both MAP and bilateral APAs from the perspective of government - via representatives from the competent authorities themselves - as well as business. MAP in particular is examined in light of new OECD statistics, various other forces that are impacting case closure statistics, and the importance the function has for MNCs from an international taxation perspective. Speakers will explore:

  • Trends in APAs and MAPs
  • Best practices in a changing tax world
  • Impact of MLI, inclusive framework etc
  • What is the role of MAP in the future
  • Arnaud Sage - Head of the APA & MAP Department (MEJEI), FRENCH COMPETENT AUTHORITY
  • Barbara Dooley - Principal Officer, Transfer Pricing Policy, IRISH REVENUE
  • Dominic Vines - Team Leader (Financial TP); Delegated Competent Authority, HMRC
  • Moderator: Joel Cooper - Co-Head International Transfer Pricing Group, DLA PIPER
More
15:35 - 16:10
Info

Ask the Experts Q&A Session

This session explores real-time audience questions and input in an interactive fashion. As conference sessions do not always have sufficient time to address the numerous interesting and divergent audience questions, this panel is dedicated to addressing this unmet need. In this session, experienced experts will select and discuss audience originated transfer pricing and tax topics, with a view of expanding the dialogue beyond the conventional approaches of a given topic. Active audience input/participation is a precondition for this session.

  • Kari Pahlman - Vice President, Global Tax and Treasury, TECHTRONICS INDUSTRIES
  • John Neighbour - Independent Transfer Pricing Consultant, INDEPENDENT
More
16:10 - 16:30

Coffee Break

More
Showing of Streams
17:50 - 19:50

Closing Remarks & Drink Reception

More