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November 2018
San Francisco


Meet Transfer Pricing professionals from across the West Coast and beyond to share insights and best practice advice on the latest TP challenges to High-Tech and Digital Economy Corporations

What's On the Agenda for 2017?

TP Challenges at the Cutting Edge of the Digital Economy

Digital economy taxation remains at the centre of OECD’s BEPS action plan with further updates expected for Action 1 by early next year. Our digital economy panel will assemble in-house transfer pricing leaders at the forefront of so called digital economy industries, such as Spotify and Uber, among others, to discuss what latest policy developments will mean for their businesses and what can be done to help shape policy in this area.

Value Chain Analysis – Not Just for Transfer Pricing Anymore

Ever since the BEPS project put value creation of the heart of the proposed changes to the international tax system, pressure has been mounting on Multinationals to unequivocally demonstrate that where profits are taxed actually corresponds to where value is created within the organization. We will endeavor to provide a comprehensive overview of the benefits and commonly applied methodologies that will lead to success when preparing your VCA in-house. 

Hard to Value Intangibles and Comparability Challenges

Intangibles, almost by definition, pose a true challenge in terms of establishing comparability.  In a post-BEPS world, where one-sided transfer pricing will no longer be sufficient, we expect more focus on proactively supporting the profits associated with intangibles. OECD's consultation on HTVI continues to fuel this timely debate, so expect up to the minute comment an analysis on how this important are is likely to develop and what it will mean for your industry.

EU State Aid Challenges in the Wake of Apple

In the wake of Apple’s historic decision by the European Commission, US multinationals will now have to seriously assess their risks and consider applicable tax rules as part of their global tax planning and negotiation of tax rulings, as well as new State Aid considerations. We will discuss the risks associated with EU State Aid in the present landscape and how these can be minimised, as well potential consequences for Silicon Valley corporations.

Financial Transactions & BEPS Action 4 - All You Need to Know

Enhance your understanding of intra-group financial transactions in light of OECD’s initiatives in this area and to what extent BEPS risks may arise in regulated banking and insurance groups in light of the robust compliance regimes already in place for the industry. Topics usually covered as part of this session include:  interest deductibility, the group ratio rule, hybrid debt instruments, tax treaty abuse, thin capitalization, and much more besides.

Transfer Pricing Controversy & ADR Opportunities

This industry panel, featuring in-house speakers from corporations such as Microsoft and others, will discuss strategies for successfully preventing, managing and resolving disputes in a post BEPS world and the challenges resulting from the increasing demand for transparency. Panellists will also examine BEPS Action 14 deliverables and give practical advice on how to minimise disputes with tax authorities and make the most of ADR opportunities.

Join Us In Fisherman’s Wharf This November

Fisherman's Wharf is one of San Francisco's most popular neighborhoods. Enjoy the benefits of a prime San Francisco location, as well as the thoughtful amenities and accommodations at the Sheraton Fisherman's Wharf Hotel. Located in Fisherman's Wharf, one of San Francisco's most beloved areas, the hotel offers superior access to some of the city's top attractions, including Pier 39, Alcatraz Island and much more.


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