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Key Sessions

Pascal Saint-Amans

In Conversation with OECD's Pascal Saint-Amans

OECD

08:30 - 08:50 20 mins
Registration & Coffee
08:50 - 09:00 10 mins
Chair's Opening Remarks
  • Ruth Steedman - Senior Managing Director, FTI CONSULTING
09:00 - 09:50 50 mins
Info
In Conversation with OECD's Pascal Saint-Amans
  • Pascal Saint-Amans - Director, Centre for Tax Policy and Administration, OECD

Pascal Saint-Amans, Director of the OECD’s Centre for Tax Policy and Administration since 2012, is globally recognised as one of the leading figures in the tax world driving the advancement of the OECD tax transparency agenda in the context of the G20 and helping redesign the global international tax landscape. Pascal will be joining us in London next year to deliver an insightful keynote session followed by and audience-led Q&A. You can put your questions to Pascal in a number of ways:

  • Ask for a microphone on the day
  • Submit your question via our Sli.do app
  • Twit us a question using the hashtag #TPMinds18
  • Email your question in advance to michele.costa@informa.com
09:50 - 10:35 45 mins
Info
The Future of Transfer Pricing Policy - Policy Makers' Insight
  • Tomas Balco - Head of Transfer Pricing Unit, OECD
  • Michael Lennard - Chief, International Tax Cooperation; Financing for Development Office, UNITED NATIONS
  • Dr Max Lienemeyer - Head of Unit, Task Force Tax Planning Practices (DG Competition), EUROPEAN COMMISSION
  • Nick Shepherd - Team Leader; TP Policy Technical Team, HMRC
  • Ian Cremer - Head of Valuation, WORLD CUSTOMS ORGANIZATION
  • Paul Morton - Tax Director, Office of Tax Simplification, HM TREASURY

How are the international organizations and Tax Administrations addressing transfer pricing and the evolving international tax landscape, including BEPS and other developments, and where do they expect them to develop in the future? This panel will examine:

  • Digital economy: There has been much discussion over the last few years of the challenges of taxing the digital economy. What are the key objectives for taxing the digital economy and to what extent is cooperation between jurisdictions necessary to successfully face these challenges
  • Blacklisted countries: It has been suggested that the EU Council’s black list of countries is too short. Should the list be extended and what are the expectations for the ‘watch list countries’? Should a significant rise in audits be expected for companies having intercompany transactions with the blacklisted countries? Should there be new anti-avoidance measures to be introduced targeted at transactions with the blacklisted countries?
  • US tax reform: What are the expectations for US tax reform? How will businesses respond to a significant fall in the US Federal tax rate? What impact ,if any, will US tax reform have on the UK from a competitive commercial perspective? Are worries about a “race to the bottom” justified?
  • BEPS peer review: How effective is the peer review process per Action 14? Is the implementation of minimum standards per Action 14 sufficient to make a meaningful difference to the timely resolution of disputes? To what extent will the best practices defined by Action 14 make a difference?
  • Tax simplification: What benefit is there for jurisdictions and taxpayers alike in simplifying taxation for governments? Is there a danger that in simplifying taxation that significant areas of “rough justice” will result? The UK has the Office for Tax Simplification; how are other countries approaching the problem?
10:35 - 10:55 20 mins
Coffee Break
10:55 - 11:35 40 mins
Info
Exchange of Information - The Challenges Facing Industry in a Transparent World
  • Andrea Tolley - VP, Global Head of Transfer Pricing, GSK
  • Desmond Webb - Deputy Group Tax Director, VODAFONE
  • Louise Sykes - SVP, Head of Transfer Pricing, XL GROUP
  • Rocío Bermúdez - Global Transfer Pricing Manager , REPSOL
  • Moderator: Andrew Cousins - Director, Transfer Pricing, DUFF & PHELPS

Country-by-Country reporting has brought the topic of transparency  and exchange of information to the forefront of the transfer pricing  world.  In the face of the global trend for ever greater transparency,  and with leaks of tax data regularly making headlines, how is industry  responding?  The panel will consider:


  • Automatic exchange of  information; spontaneous exchange; exchange on request: What kind of  information is being exchanged between governments
  • Are we seeing a change of approach from tax administrations as a result of the new tools at their disposal?
  • How is information exchange affecting behaviour in industry? Will the old ways still work?
  • Information leaks – preparing for breaches of confidentiality
11:35 - 12:05 30 mins
Info
Transfer Pricing Challenges of the Digital Economy - 2018 Status and Outlook
  • Jens Svolgaard - Vice President Tax, SPOTIFY
  • Interim (local/regional) solutions
  • Equalisation levies, digital withholding taxes and other great! ideas
  • Permanent "solution"
  • Digital permanent establishment - value creation/value chain analysis

    Buckle up world, it will be a looong and very bumpy ride!
12:05 - 12:45 40 mins
Info
Taxing the Digital Economy - How Should Industry Respond to the Latest Initiatives from OECD and EU
  • Francois Chadwick - Global Head of Tax & Accounting, UBER
  • Jens Svolgaard - Vice President Tax, SPOTIFY
  • Anne Oliver - Finance Director, Global Tax, SKYSCANNER
  • Georg Gam-Jensen - Transfer Pricing Specialist, BESTSELLER
  • Tim Mathey - Director European Tax, ELECTRONIC ARTS
  • Moderator: Kirsty Rockall - Partner, KPMG

Digital economy taxation remains at the centre of OECD’s BEPS action plan with further developments expected for Action 1 by early next year. At the same time, the European Commission has launched a new EU agenda to ensure a coherent EU approach to taxing the digital economy. This panel will assemble in-house transfer pricing experts at the forefront of the digital economy to discuss what the latest policy developments will mean for their business, how industry should respond to these challenges and how it might be possible to help shape policy in this area. Coverage includes:

  • What is the digital economy?
  • Interaction between the OECD, EU Commission and individual nation states as they seek to apply tax to the digital economy
  • Dispelling the myth that highly digitalised companies are not paying their ‘fair share of tax’
  • Is the movement towards source-based taxation rights, a movement in the right direction?
  • Beyond transfer pricing: legal and other tax considerations of the impact of taxing the digital economy
12:45 - 13:55 70 mins
Info
Lunch

Conference Luncheon sponsored by S&P Global Market Intelligence

13:55 - 14:35 40 mins
Info
The New TP Risk Paradigm - Where Are the New Risks Coming From and are There Any Blind Spots?
  • Tim Brierley - GM Global Tax, SABIC
  • Manisha Pande - Transfer Pricing Director, BAKER HUGHES
  • Gabriella Cappelleri - Of Counsel, MAISTO
  • Ian Brimicombe - SVP Tax, BURBERRY
  • Fred Lo - Vice President, Global Head of Tax, YANFENG AUTOMOTIVE INTERIORS
  • Moderator: Lesley Holstead - Global Tax Solutions Lead, HUAWEI

Industry speakers share their insights into where the new tax and TP risks are likely to come from and discuss potential “blind spots”. Panellists will also 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.

14:35 - 15:15 40 mins
Info
Latest Developments with APAs - The Competent Authorities' Perspective
  • Monica Todose - Director of Transfer Pricing and Tax Rulings Directorate, ROMANIAN NATIONAL AGENCY FOR TAX ADMINISTRATION
  • Simone Di Vaia - Large Taxpayers Directorate, Head of Advance agreements and International Disputes Office (Rome Unit), ITALIAN TAX AGENCY
  • Nicholas Stevart - APA Lead, HMRC
  • Norbert Roller - Of Counsel; Former Austrian Competent Authority, DLA PIPER
  • Moderator: Randall Fox - Co-Head of Transfer Pricing, DLA PIPER

Leading experts on APAs from both the private and public sector discuss global trends concerning APAs, including the increasing appeal of bilateral APAs as a tool for certainty post-BEPS and the impact of State aid and other EC developments on unilateral APAs. Strategies for obtaining certainty through APAs, in efficient and cost-effective ways, as well as tips and tricks for speeding up the process through the use of technology and other means will be discussed.

15:15 - 15:55 40 mins
Info
Agency PEs - A Case Study
  • Karine Halimi-Guez - Managing Director, Tax, FEDEX

Karine Halimi-Guez of FedEx is back on the TP Minds stage with yet another insightful and dynamic presentation. The solo session will take a detailed look at Agency PE and its relation with transfer pricing. Areas under review include:


• Definitions and key past court decisions
• How BEPS closed certain loopholes
• We have an agency. Now what? - Profit attribution and transfer pricing
• A practical experience of agency PE review

15:55 - 16:15 20 mins
Coffee Break
16:15 - 16:55 40 mins
Info
Stream A
Managing Permanent Establishments Risk
  • Abhijay Bhatia - Transfer Pricing Manager, EMEA, INTEL CORPORATION
  • Rocío Bermúdez - Global Transfer Pricing Manager , REPSOL
  • Pierre Meunier - Co-Head of Transfer Pricing, BNP PARIBAS
  • Denis Philippov - Senior Transfer Pricing Advisor, GAZPROM
  • Matthew Herrington - Partner, KPMG

The OECD’s BEPS project has precipitated a heightened focus on PE thresholds by tax administrations all over the world. A patchwork of divergent approaches is already springing up, as each country begins to adopt its own unique tax base defence response to Action 7. Whether following approaches set out in the Multilateral Instrument, or by taking unilateral domestic action, tax administrations are now increasingly ready and equipped to challenge PE status. And for multinationals operating across borders, PE challenges are coming to dominate their global tax controversy disputes. This session will survey the recent international developments in this space, explain key indicators of PE risk, and provide practical steps that multinational groups can be taking in order to mitigate risk, defend positions, and ensure the robustness of their global ETR strategy. Attend this session to gain an insight into:

  • Current trends in PE status, including updates on the multilateral instrument and unilateral actions such as DPT and MAAL
  • Key indicators of PE risk based on prevailing OECD and UN standards
  • An overview of the OECD’s revised draft guidance concerning the attribution of profits to PEs
  • Practical steps that can be taken to address risk in this area; and
  • Recent experience of handling tax administration challenges in relation to PE thresholds
16:15 - 16:55 40 mins
Info
Stream B
Impact of the U.S. Tax Reform on Transfer Pricing Planning
  • George Georgiev, Ph.D. - Senior Director, Transfer Pricing and Economic Analyses, SIEMENS
  • Kari Pahlman - Vice President, Global Tax and Treasury, TECHTRONICS INDUSTRIES
  • Glyn Fullelove - Group Tax Director, INFORMA
  • Moderator: Elizabeth Stevens - Associate, CAPLIN & DRYSDALE

The U.S. Tax Reform is likely to have substantial impact on the tax arrangements of countless multinationals. The speed at which the U.S. passed the tax reform through
Congress has left a very short window for multinational companies to assess what the impact of many of these changes will be on current structures as well as planned changes under the legislation. It is therefore critical to understand the impact and scope of the U.S. Tax Reform in reference to a number of key areas, which industry panellists will explore as part of this session.

16:15 - 16:55 40 mins
Info
Stream C
Transfer Pricing Technology: How to Define, Defend and Build Consensus for an Automation Project
  • Sam Cicogna - VP & Head ONESOURCE Transfer Pricing, THOMSON REUTERS
  • Jacobo Gonzalez - Operational Transfer Pricing IT Project Lead, DUPONT

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.

16:55 - 17:35 40 mins
Info
Stream A
Practical Experiences with CbCR, Local File/Master File Implementation
  • Kristine Ilstad - Head of Transfer Pricing, DNB BANK
  • Jose Luis Migoya Vargas - International Tax Director, IBERDROLA
  • Lukasz Kubicki - Head of International Tax, OERLIKON
  • Mimi Song - VP - Professional Services, CROSSBORDER SOLUTIONS
  • Moderator: Wendy Nicholls - Head of Transfer Pricing, GRANT THORNTON

As CbCR comes into effect this will be the first opportunity for  multinationals to discuss their initial experiences with BEPS Action 13  as well as the practical challenges encountered with Local File/Master  File Implementation. Industry panellists will share practical  experiences and also discuss the role of technology as part of the new  reporting process. The session will explore:

  • How large groups have approached the project
  • Collation and checking your data
  • Managing notifications and deadlines
  • Managing the message to tax authorities
16:55 - 17:35 40 mins
Info
Stream B
Indirect Tax & Customs Issues Post-Brexit
  • Moderator: Matthew Fleming - Partner, Tax Disputes & International Trade, KPMG
  • Alan McLintock - Senior Manager, European Indirect Tax Strategy, FORD
  • Jeremy Cape - Partner, SQUIRE PATTON BOGGS
  • Ian Brimicombe - SVP Tax, BURBERRY

This session will explore the indirect tax implications of Brexit on supply chains and discuss what businesses should be doing now to meet the new challenges to their current arrangements. As a customs border between the UK and EU seems increasingly likely resulting in higher costs of trading and profitability, panellists will come together to discuss common challenges and alternative operating models.

16:55 - 17:35 40 mins
Info
Stream C
Tax & Transfer Pricing Automation Solutions v 2.0 – Plug & Play v Bespoke
  • John Farooque Dar - CEO and Co-founder, INTERCOMPANY SOFTWARE
  • Dorene Niotakis - General Manager, Corporate Reporting Solutions, WOLTERS KLUWER
  • Time to cancel the automation party or to invite more to the party?
  • Understanding the key concepts: Automation, Robotics, Machine Learning, AI
  • Technical issues and process challenges that can be solved with automation
  • Tax and transfer pricing case studies
17:35 - 19:35 120 mins
Closing Remarks & Drink Reception
08:30 - 08:50

Registration & Coffee

More
08:50 - 09:00
Info

Chair's Opening Remarks

  • Ruth Steedman - Senior Managing Director, FTI CONSULTING
More
09:00 - 09:50
Info

In Conversation with OECD's Pascal Saint-Amans

Pascal Saint-Amans, Director of the OECD’s Centre for Tax Policy and Administration since 2012, is globally recognised as one of the leading figures in the tax world driving the advancement of the OECD tax transparency agenda in the context of the G20 and helping redesign the global international tax landscape. Pascal will be joining us in London next year to deliver an insightful keynote session followed by and audience-led Q&A. You can put your questions to Pascal in a number of ways:

  • Ask for a microphone on the day
  • Submit your question via our Sli.do app
  • Twit us a question using the hashtag #TPMinds18
  • Email your question in advance to michele.costa@informa.com
  • Pascal Saint-Amans - Director, Centre for Tax Policy and Administration, OECD
More
09:50 - 10:35
Info

The Future of Transfer Pricing Policy - Policy Makers' Insight

How are the international organizations and Tax Administrations addressing transfer pricing and the evolving international tax landscape, including BEPS and other developments, and where do they expect them to develop in the future? This panel will examine:

  • Digital economy: There has been much discussion over the last few years of the challenges of taxing the digital economy. What are the key objectives for taxing the digital economy and to what extent is cooperation between jurisdictions necessary to successfully face these challenges
  • Blacklisted countries: It has been suggested that the EU Council’s black list of countries is too short. Should the list be extended and what are the expectations for the ‘watch list countries’? Should a significant rise in audits be expected for companies having intercompany transactions with the blacklisted countries? Should there be new anti-avoidance measures to be introduced targeted at transactions with the blacklisted countries?
  • US tax reform: What are the expectations for US tax reform? How will businesses respond to a significant fall in the US Federal tax rate? What impact ,if any, will US tax reform have on the UK from a competitive commercial perspective? Are worries about a “race to the bottom” justified?
  • BEPS peer review: How effective is the peer review process per Action 14? Is the implementation of minimum standards per Action 14 sufficient to make a meaningful difference to the timely resolution of disputes? To what extent will the best practices defined by Action 14 make a difference?
  • Tax simplification: What benefit is there for jurisdictions and taxpayers alike in simplifying taxation for governments? Is there a danger that in simplifying taxation that significant areas of “rough justice” will result? The UK has the Office for Tax Simplification; how are other countries approaching the problem?
  • Tomas Balco - Head of Transfer Pricing Unit, OECD
  • Michael Lennard - Chief, International Tax Cooperation; Financing for Development Office, UNITED NATIONS
  • Dr Max Lienemeyer - Head of Unit, Task Force Tax Planning Practices (DG Competition), EUROPEAN COMMISSION
  • Nick Shepherd - Team Leader; TP Policy Technical Team, HMRC
  • Ian Cremer - Head of Valuation, WORLD CUSTOMS ORGANIZATION
  • Paul Morton - Tax Director, Office of Tax Simplification, HM TREASURY
More
10:35 - 10:55

Coffee Break

More
10:55 - 11:35
Info

Exchange of Information - The Challenges Facing Industry in a Transparent World

Country-by-Country reporting has brought the topic of transparency  and exchange of information to the forefront of the transfer pricing  world.  In the face of the global trend for ever greater transparency,  and with leaks of tax data regularly making headlines, how is industry  responding?  The panel will consider:


  • Automatic exchange of  information; spontaneous exchange; exchange on request: What kind of  information is being exchanged between governments
  • Are we seeing a change of approach from tax administrations as a result of the new tools at their disposal?
  • How is information exchange affecting behaviour in industry? Will the old ways still work?
  • Information leaks – preparing for breaches of confidentiality
  • Andrea Tolley - VP, Global Head of Transfer Pricing, GSK
  • Desmond Webb - Deputy Group Tax Director, VODAFONE
  • Louise Sykes - SVP, Head of Transfer Pricing, XL GROUP
  • Rocío Bermúdez - Global Transfer Pricing Manager , REPSOL
  • Moderator: Andrew Cousins - Director, Transfer Pricing, DUFF & PHELPS
More
11:35 - 12:05
Info

Transfer Pricing Challenges of the Digital Economy - 2018 Status and Outlook

  • Interim (local/regional) solutions
  • Equalisation levies, digital withholding taxes and other great! ideas
  • Permanent "solution"
  • Digital permanent establishment - value creation/value chain analysis

    Buckle up world, it will be a looong and very bumpy ride!
  • Jens Svolgaard - Vice President Tax, SPOTIFY
More
12:05 - 12:45
Info

Taxing the Digital Economy - How Should Industry Respond to the Latest Initiatives from OECD and EU

Digital economy taxation remains at the centre of OECD’s BEPS action plan with further developments expected for Action 1 by early next year. At the same time, the European Commission has launched a new EU agenda to ensure a coherent EU approach to taxing the digital economy. This panel will assemble in-house transfer pricing experts at the forefront of the digital economy to discuss what the latest policy developments will mean for their business, how industry should respond to these challenges and how it might be possible to help shape policy in this area. Coverage includes:

  • What is the digital economy?
  • Interaction between the OECD, EU Commission and individual nation states as they seek to apply tax to the digital economy
  • Dispelling the myth that highly digitalised companies are not paying their ‘fair share of tax’
  • Is the movement towards source-based taxation rights, a movement in the right direction?
  • Beyond transfer pricing: legal and other tax considerations of the impact of taxing the digital economy
  • Francois Chadwick - Global Head of Tax & Accounting, UBER
  • Jens Svolgaard - Vice President Tax, SPOTIFY
  • Anne Oliver - Finance Director, Global Tax, SKYSCANNER
  • Georg Gam-Jensen - Transfer Pricing Specialist, BESTSELLER
  • Tim Mathey - Director European Tax, ELECTRONIC ARTS
  • Moderator: Kirsty Rockall - Partner, KPMG
More
12:45 - 13:55
Info

Lunch

Conference Luncheon sponsored by S&P Global Market Intelligence

More
13:55 - 14:35
Info

The New TP Risk Paradigm - Where Are the New Risks Coming From and are There Any Blind Spots?

Industry speakers share their insights into where the new tax and TP risks are likely to come from and discuss potential “blind spots”. Panellists will also 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.

  • Tim Brierley - GM Global Tax, SABIC
  • Manisha Pande - Transfer Pricing Director, BAKER HUGHES
  • Gabriella Cappelleri - Of Counsel, MAISTO
  • Ian Brimicombe - SVP Tax, BURBERRY
  • Fred Lo - Vice President, Global Head of Tax, YANFENG AUTOMOTIVE INTERIORS
  • Moderator: Lesley Holstead - Global Tax Solutions Lead, HUAWEI
More
14:35 - 15:15
Info

Latest Developments with APAs - The Competent Authorities' Perspective

Leading experts on APAs from both the private and public sector discuss global trends concerning APAs, including the increasing appeal of bilateral APAs as a tool for certainty post-BEPS and the impact of State aid and other EC developments on unilateral APAs. Strategies for obtaining certainty through APAs, in efficient and cost-effective ways, as well as tips and tricks for speeding up the process through the use of technology and other means will be discussed.

  • Monica Todose - Director of Transfer Pricing and Tax Rulings Directorate, ROMANIAN NATIONAL AGENCY FOR TAX ADMINISTRATION
  • Simone Di Vaia - Large Taxpayers Directorate, Head of Advance agreements and International Disputes Office (Rome Unit), ITALIAN TAX AGENCY
  • Nicholas Stevart - APA Lead, HMRC
  • Norbert Roller - Of Counsel; Former Austrian Competent Authority, DLA PIPER
  • Moderator: Randall Fox - Co-Head of Transfer Pricing, DLA PIPER
More
15:15 - 15:55
Info

Agency PEs - A Case Study

Karine Halimi-Guez of FedEx is back on the TP Minds stage with yet another insightful and dynamic presentation. The solo session will take a detailed look at Agency PE and its relation with transfer pricing. Areas under review include:


• Definitions and key past court decisions
• How BEPS closed certain loopholes
• We have an agency. Now what? - Profit attribution and transfer pricing
• A practical experience of agency PE review

  • Karine Halimi-Guez - Managing Director, Tax, FEDEX
More
15:55 - 16:15

Coffee Break

More
Showing of Streams
17:35 - 19:35

Closing Remarks & Drink Reception

More