AGENDA

Day One | Day Two

 

DAY ONE: MONDAY 27 MARCH 2017

8:30 AM – 9:15 AM     Breakfast and Registration

9:15 AM – 10:00 AM     Will the Profit Split Method Gain Traction?
Guidance on the use of the profit split method is one of the items of unfinished business under the BEPS project and the new profit split guidance will be the culmination of the work on risks and intangibles performed in the context of the BEPS project. The July 2016 OECD discussion draft leaves many questions unanswered, especially regarding a possible broadening of the cases of application of the profit split method to entities performing "DEMPE" functions or controlling risk. It further contains new draft guidance on how to apply the profit split method, with a particular emphasis on ex ante versus ex post approaches. This session will review the latest OECD work on profit split as well as trends observed in audits and APAs in relation to profit split, as well as observed and expected trends in OECD and non-OECD countries.

Moderator: Caroline Silberztein, Chair, Global Transfer Pricing, Baker McKenzie

Panelists:

  • Holly Glenn, Principal Economist, Baker McKenzie
  • Brian Jenn, Attorney Advisor, Office of International Tax Counsel, U.S. Department of Treasury
  • Carlos Pérez Gómez Serrano, Head of Transfer Pricing, Mexican Tax Administration Service
  • Catherine Turk, Senior Director, Global Tax Planning, Johnson & Johnson
  • Thierry Steininger, Deputy Group Head of Tax, Nestlé, Geneva

10:00 AM – 10:45 AM     Profit Split Method: Case Study 
This session will analyze the most current guidance on profit splits through a case study.

Moderator: Caroline Silberztein, Chair, Global Transfer Pricing, Baker McKenzie

Panelists:

  • Holly Glenn, Principal Economist, Baker McKenzie
  • Brian Jenn, Attorney Advisor, Office of International Tax Counsel, U.S. Department of Treasury
  • Catherine Turk, Senior Director, Global Tax Planning, Johnson & Johnson
  • Thierry Steininger, Deputy Group Head of Tax, Nestlé, Geneva

10:45 AM – 11:30 PM     Break for Refreshments

11:30 AM – 12:00 PM     Keynote Address: Robert Stack, Former Deputy Assistant Secretary (International Tax Affairs), U.S. Department of Treasury

12:00 PM – 1:00 PM     Transfer Pricing and Developing Countries: The UN Manual and the OECD’s ‘Inclusive Framework’ 
In recent years, there have been parallel efforts at the United Nations and the OECD to make transfer pricing guidance relevant for all countries, including developing economies with limited audit resources and limited access to the comparable data needed for a traditional transfer pricing analysis. At the UN, this effort has taken the form of a Practical Manual on Transfer Pricing for Developing Countries. More recently, the OECD has developed an “inclusive framework” to encourage as many countries as possible to adopt recommendations from the BEPS project. This session will examine both efforts and their impact on transfer pricing regimes around the world.

Moderator: Carol Dunahoo, Partner, Baker McKenzie

Panelists:

  • Andreas Guenster, Group Tax & Transfer Pricing Manager, Puma Energy
  • Nishana Gosai, Senior Executive: Transfer Pricing, Baker McKenzie
  • Sanjiv Malhotra, Director of Economics, Baker McKenzie, Singapore
  • Stig Sollund, Director at Ministry of Finance, Head of International Tax Section, Tax Law, Norway (UN Tax Committee, Transfer Pricing Subgroup Coordinator)
  • Melinda Brown, Senior Transfer Pricing Advisor, OECD Centre for Tax Policy and Administration (CTPA)

1:00 PM – 2:00 PM     Luncheon

2:00 PM – 2:30 PM     Transfer Pricing Documentation: Aligning the Master File, Local File and Country-by-Country Report
Countries around the world are adopting the OECD’s three-pronged documentation approach of a master file, local file and country-by-country report. The new requirements raise a host of issues, from discrepancies in countries’ effective dates to substantive differences in their interpretation of the Action 13 guidance, with some countries, including China, using it to justify an analysis of the company’s value chain.

Moderator: Molly Moses, Managing Editor, Transfer Pricing Report, think and code

Panelists:

  • William Morris, Director, Global Tax Policy, GE
  • Brian Jenn, Attorney Advisor, Office of International Tax Counsel, U.S. Department of Treasury
  • Paul Morton, Tax Director of the Office of Tax Simplification, HM Treasury (formerly Head of Group Tax RELX Group)
  • Shanwu Yuan, International Tax Director, Baker McKenzie

2:30 PM – 3:30 PM     Value Chain Analyses: A New Panacea or a Non-Event?
In its July 2016 discussion draft on profit split, the OECD included a rather long discussion of Value Chain Analyses ("VCAs") which it presented as having the potential to assist in the accuratre delineation of the transaction, the selection of the most appropriate transfer pricing method and the application of profit split methods (to identify both the profits to be split and the splitting factors). China SAT is now requiring VCAs as part of its transfer pricing documentation requirements. VCAs were however not part of the OECD-G20 Action 13 Final Report released in October 2015. Although VCAs are a well-known analytical tool for economists, fundamental questions arise as to what exactly tax administrations may expect to be provided with and how they may use VCAs while applying the arm's length principle.

Moderator: Richard Fletcher, Principal Tax Advisor, Baker McKenzie

Panelists:

  • Béatrice Deshayes-Van Wichelen, Group Tax Director, LVMH
  • Paul Morton, Tax Director of the Office of Tax Simplification, HM Treasury (formerly Head of Group Tax RELX Group)
  • Moiz A. Shirazi, Director of Economics & Financial Advisory Services, Baker McKenzie Consulting LLC
  • Jefferson VanderWolk, Head of Tax Treaty, Transfer Pricing and Financial Transactions Division, OECD
  • William Morris, Director, Global Tax Policy, GE

3:30 PM – 4:00 PM     Break for Refreshments

4:00 PM – 4:45 PM     PE Profit Attribution: From Preventing ‘Double Non-Taxation’ to Triggering Triple Taxation—or More?
The OECD's new standard for defining permanent establishments has created a risk that a company's profits could be taxed multiple times as many jurisdictions target the same income stream. This session will examine the circumstances under which PE will be triggered and how profits should be attributed to new forms of PEs under the most recent guidance.

Moderator: Mary Bennett, Tax Partner, Baker McKenzie

Panelists:

  • Michael McDonald, Financial Economist, Office of Tax Analysis, U.S. Department of Treasury
  • William Morris, Director, Global Tax Policy, GE
  • Timothy Power, Deputy Director, Corporate Tax (Business and International Tax), HM Treasury
  • Gary D. Sprague, Partner, Baker McKenzie
  • Jefferson VanderWolk, Head of Tax Treaty, Transfer Pricing and Financial Transactions Division, OECD

4:45 PM – 5:30 PM     PE Profit Attribution: Case Study
Panelists will illustrate PE risk through a case study.

Moderator: Mary Bennett, Tax Partner, Baker McKenzie

Panelists:

  • Michael McDonald, Financial Economist, Office of Tax Analysis, U.S. Department of Treasury
  • William Morris, Director, Global Tax Policy, GE
  • Timothy Power, Deputy Director, Corporate Tax (Business and International Tax), HM Treasury
  • Gary D. Sprague, Partner, Baker McKenzie
  • Jefferson VanderWolk, Head of Tax Treaty, Transfer Pricing and Financial Transactions Division, OECD

5:30 PM     Networking Reception


DAY TWO: TUESDAY 28 MARCH 2017

8:15 AM – 9:00 AM     Breakfast and Registration

9:00 AM – 9:30 AM     Keynote Address: Gert-Jan Koopman, Deputy Director-General for State Aid, European Commission

9:30 AM – 10:30 AM     European Union: State Aid Cases, Legislative Reaction to BEPS, Plans for a Common Tax Base and More
The tax probes by the European Commission’s competition Commissioner continue, throwing long-standing transfer pricing practice into doubt. Independent of those investigations, the commission is implementing its Anti-Tax Avoidance Directive to adopt many of the OECD’s BEPS recommendations, and is also considering a requirement for public country-by-country reporting. Its initiative for a common consolidated corporate tax base, meanwhile, could represent a radical departure from a traditional transfer pricing approach with a second step that calls for formulary apportionment.

Moderator: Kevin Bell, Senior Reporter, Transfer Pricing, think and code

Panelists:

  • Alfred de Lassence, Vice President, Tax, Air Liquide
  • Gert-Jan Koopman, Deputy Director-General for State Aid, European Commission
  • Antonio Russo, Principal, Baker McKenzie
  • Robert Stack, Former Deputy Assistant Secretary (International Tax Affairs), U.S. Department of Treasury
  • Joseph Duffy, Partner, Tax, Matheson

10:30 AM – 11:30 AM     "DEMPE" Functions: Recent Experience
The OECD’s final BEPS guidance on intangibles requires members of a multinational group to be compensated for functions performed in the “development, enhancement, maintenance, protection and exploitation” of intangibles. This session will look at topics including recent experience in applying this concept in the light of developing patent box regimes, other centralized IP ownership structures, and the impact of matrix organizations on tax risk management.

Moderator: Margreet Nijhof, Partner, Baker McKenzie

Panelists:

  • Catherine Harlow, Head of Transfer Pricing, RELX Group
  • Jukka Karjalainen, Tax Leader Business Transformations-Transfer Pricing Group, Baker McKenzie
  • Michael McDonald, Financial Economist, Office of Tax Analysis, U.S. Department of Treasury
  • Scarlet Pereira, Senior Vice President, Tax Planning and Compliance, International, Mastercard

11:30 AM – 12:00 PM     Break for Refreshments

12:00 PM – 1:00 PM     Financing Transactions and the Arm's Length Principle: Where Do We Stand?
The OECD Working Party No. 6 has resumed work on the transfer pricing aspects of financing transactions. The interaction of the arm's length principle with intragroup financing, including assessment of thin or thick capitalization, determination of interest rates and how to reflect implicit and explicit guarantees are an area of significant uncertainty. This session will take stock of existing international guidance and case law and look at OECD anticipated guidance.

Moderator: Steve Labrum, Principal Tax Advisor, Baker McKenzie

Panelists:

  • Antonio Weffer, Tax Director, Baker McKenzie
  • Timothy Berger, Executive Vice President, Tax, Mastercard
  • Brian Jenn, Attorney Advisor, Office of International Tax Counsel, U.S. Department of Treasury

1:00 PM – 2:00 PM     Luncheon

2:00 PM     Conference Concludes

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