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Managing Global Tax Disputes Summit 2021

May 18-20, virtual event | BST (British Summer Time)

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ABOUT THIS EVENT

The ITR Managing Global Tax Disputes Summit 2021 took place virtually over three days on May 18-20, providing insight into the key issues and developments on tax dispute trends.

 

Driven largely by the OECD’s BEPS Action Plan, the last decade has seen a huge increase in the number of tax disputes and audits. Although the past year has seen some slowdown due to the impact of COVID-19, activity is expected to rise sharply as both tax authorities and taxpayers act under pressure to raise cash, escalating potential for disputes.

 

As the landscape develops post-COVID, it will be more important than ever for tax practitioners to effectively manage the prevention, negotiation and resolution of disputes. This event will provide the opportunity to discuss practical and strategic steps for taxpayers facing an increasingly complex controversy environment in Europe and beyond.
ATTENDEE PROFILE
200+ tax professionals
200+ TAX PROFESSIONALS
Tax professionals
TAX EXECUTIVE AUDIENCE
Networking
INTERNATIONAL NETWORK

VIRTUAL EVENT FEATURES

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AGENDA

May 18
May 19
May 20

Tuesday, May 18

Opening comments from ITR
12.30 - 12.35 BST

Keynote address: latest developments in tax certainty

12.35 - 13.00 BST
Sandra Knaepen is directly responsible for work concerning dispute resolution at the OECD and will provide delegates with a timely update on the latest developments.
Sandra Knaepen
Sandra Knaepen
head of unit, OECD
Networking break
13.00 - 13.20 BST

Managing tax disputes in uncertain times

13.20 - 14.10 BST
  • Assessing the tax dispute landscape post-pandemic
  • Post-COVID audit management
  • Brexit: what will the relationship between the UK and the EU look like moving forward? How will this impact dispute prevention and resolution?
  • Other key geopolitical developments
Jennifer Breeze
Jennifer Breeze
transfer pricing director, Deloitte (moderator)
Samir Yahiaoui
Samir Yahiaoui
director, tax, Deloitte
Mark Houtzager
Mark Houtzager
EMEA tax leader, Starbucks
Darren Meredith
Darren Meredith
VP tax planning, BP
Networking break
14.10 - 14.30 BST

Transfer pricing and related tax disputes activities

14.30 - 15.20 BST
  • Long-term transfer pricing implications of COVID-19: dealing with aggressive TP audits and extensive requests for information
  • Litigation: how will tax authorities and taxpayers manage the knock-on effect of delayed cases?
  • Dispute prevention: negotiating APAs
Jessica Eden
Jessica Eden
partner, Baker McKenzie (moderator)
Nigel Dolman
Nigel Dolman
principal, Baker McKenzie
Catherine Harlow
Catherine Harlow
head of transfer pricing, AstraZeneca
Markus Schneider
Markus Schneider
global tax manager, group TP controversy, Bayer
Don Maher
Don Maher
vice president taxes, Mohawk Industries
Close of day one
15.20 BST
Back to top
May 18
May 19
May 20

Wednesday, May 19

Opening comments from ITR
12.30 - 12.35 BST

Handling international tax disputes

12.35 - 13.25 BST
  • How has BEPS changed the TP controversy landscape?
  • Coming From Left Field – new areas of TP audit including, indirect tax and international commercial arbitration
  • Organising for future TP audits
Niraja Srinivasan
Niraja Srinivasan
director, NERA Economic Consulting (moderator)
Emmanuel Llinares
Emmanuel Llinares
head of global transfer pricing, NERA Economic Consulting
Erik Knijnenburg
Erik Knijnenburg
global head of tax and TP, H&M
Massimo Mojana
Massimo Mojana
head of tax, IMI Hydronic Engineering
Kamila Szydlowska
Kamila Szydlowska
senior tax director EMEA, Bausch Health Companies
Networking break
13.25 - 13.45 BST

Digitalisation, disputes and double taxation

13.45 - 14.35 BST
  • How can taxpayers prepare for the increased risk of double taxation presented by DSTs and the OECD’s Pillar 1 and 2?
  • Tips for approaching disputes on double taxation
  • Using MAP to resolve disputes arising from Pillar 1 and Pillar 2 proposals
David Forst
David Forst
partner, Fenwick & West (moderator)
Mike Knobler
Mike Knobler
associate, Fenwick & West
Donata Koren
Donata Koren
global head of tax, Zalando
Carlos Enrech
Carlos Enrech
head of tax UK&I, Ferrovial
Close of day two
14.35 BST
Back to top
May 18
May 19
May 20

Thursday, May 20

Opening comments from ITR
12.30 - 12.35 BST

Managing tax authority relationships

12.35 - 13.25 BST
  • Advice for maintaining positive relationships with tax authorities
  • Working with local advisers
  • How do you find the right balance of information sharing?
  • Tips for negotiating settlements
Josh White
Josh White
acting managing editor, ITR (moderator)
Jian-Cheng Ku
Jian-Cheng Ku
partner, DLA Piper
Nathaniel Carden
Nathaniel Carden
partner, international tax and tax controversy,  Skadden
Parmesh Rajani
Parmesh Rajani
head of transfer pricing, Kingfisher
Greg Leathes
Greg Leathes
Head of Tax EMEA, LEGO Group
Networking break
13.25 - 13.45 BST

Talking to the board about the risks of disputes

13.45 - 14.35 BST
  • Explaining disputes and controversy risks to the wider organisation and business partners
  • Creating constructive conversation with the Board around ways to mitigate risk
  • Importance of clearly stating expectations on dispute management with service providers
Sam Dames
Sam Dames
tax partner, CMS (moderator)
Jose Olvera Salcedo
Jose Olvera Salcedo
head of tax, Hitachi Europe
Giolla Kiely
Giolla Kiely
head of tax, CDB Aviation
Gerard Franklin
Gerard Franklin
Managing Director – Tax, Accounting & Treasury, Tishman Speyer
Networking break
14.35 - 14.55 BST

Finding and implementing the shortest route to resolution

14.55 - 15.45 BST
  • Mutual agreement procedures (MAP): is this the most productive route for taxpayers?
  • Assessing local in-country resolution options
  • Alternative methods: safe harbour options, treaty provisions
Kim Boylan
Kim Boylan
partner, White & Case (moderator)
Brian Gleicher
Brian Gleicher
partner, White & Case
Erik Knijnenburg
Erik Knijnenburg
global head of tax & TP, H&M
Close of conference
15.45 BST
Back to top

SPEAKERS

If you feel you have something to contribute or would like to position yourself as an expert in your field, please get in touch with Lucy Huckle for in-house speaking enquiries or Jamil Ahad for law firm or service provider opportunities.
Sandra Knaepen
Sandra Knaepen
OECD
Learn more ›
Sandra Knaepen

head of unit, CbC reporting / tax certainty, OECD



Sandra Knaepen is directly responsible for work concerning dispute resolution at the OECD and will be proving the delegates with a timely update on the latest developments



 Speaking session 


Keynote address: latest developments in tax certainty

Tuesday, May 18 - 12.35 - 13.00 BST

Kim Boylan
Kim Boylan
White & Case
Learn more ›
Kim Boylan

partner, White & Case



TBC



 Speaking session 


Finding and implementing the shortest route to resolution

Thursday, May 20 - 14.55 - 15.45 BST

Jennifer Breeze
Jennifer Breeze
Deloitte
Learn more ›
Jennifer Breeze

transfer pricing director, Deloitte



Jen Breeze is a Director in the London Transfer Pricing team and works on complex transfer pricing matters for a variety of clients. In addition to designing and supporting robust transfer pricing policies, she has extensive experience in all aspects of transfer pricing controversy including dealing with transfer pricing audits, resolving double tax through Mutual Agreement Procedures (MAPs) and avoiding double tax through Advance Pricing Agreements (APAs).


 Speaking session 


Managing tax disputes in uncertain times

Tuesday, May 18 - 13.20 - 14.10 BST

Nathaniel Carden
Nathaniel Carden
Skadden
Learn more ›
Nathaniel Carden

partner, international tax and tax controversy, Skadden



Nate Carden focuses on both planning and controversies arising in connection with transfer pricing and related international tax issues. Building on several years of experience as a management consultant with McKinsey & Co. and serving as a law clerk for The Honorable Diane P. Wood of the United States Court of Appeals for the Seventh Circuit, Mr. Carden specifically concentrates on the tax aspects of ongoing business operations. He works with corporate and other clients across many industries, with a particular focus on life science, health care and technology companies.



 Speaking session 


Managing tax authority relationships

Thursday, May 20 - 12.35 - 13.25 BST

Jian-Cheng Ku
Jian-Cheng Ku
DLA Piper
Learn more ›
Jian-Cheng Ku

partner, DLA Piper



TBC



 Speaking session 


Managing tax authority relationships

Thursday, May 20 - 12.35 - 13.25 BST

Sam Dames
Sam Dames
CMS
Learn more ›
Sam Dames

tax partner, CMS



TBC



 Speaking session 


Talking to the board about the risks of disputes

Thursday, May 20 - 13.45 - 14.35 BST

Nigel Dolman
Nigel Dolman
Baker McKenzie
Learn more ›
Nigel Dolman

principal, Baker McKenzie



Nigel co-leads both the Transfer Pricing and Tax Disputes teams in London. He also leads the Valuations practice. He joined the Firm in 2009, having previously worked in EY's transfer pricing and supply chain team for 10 years. Nigel advises clients on global transfer pricing matters, focusing on the design and defence of transfer pricing policies. Nigel has focussed heavily on Tax Disputes over the last few years and has successfully settled a number of high-value, high-profile audits. He has also helped clients to implement business restructuring arrangements with tax effective transfer pricing designs.



 Speaking session 


Transfer pricing and related tax disputes activities

Tuesday, May 18 - 14.30 - 15.20 BST

Jessica Eden
Jessica Eden
Baker McKenzie
Learn more ›
Jessica Eden

partner, Baker McKenzie



Jessica is a Partner and co-leads the Tax Disputes team in London. She is a tax lawyer as well as an accredited CEDR accredited mediator. She has a wealth of experience in handling HMRC investigations into complex international structures, concerning questions of transfer pricing, interest deductibility and double tax treaty relief. In addition to her broad international tax enquiries practice, seeking to achieve resolution through negotiated settlement and other ADR techniques, Jessica also acts on cases in the Tax Tribunal and higher courts involving domestic UK corporation tax matters and advises clients on defending their public law rights through Judicial Review in the administrative courts.



 Speaking session 


Transfer pricing and related tax disputes activities

Tuesday, May 18 - 14.30 - 15.20 BST

David Forst
David Forst
Fenwick & West
Learn more ›
David Forst

partner, Fenwick & West



David focuses on international corporate taxation. David has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. David is included in Euromoney’s Tax Advisors Expert Guides (World’s Leading Tax Advisors, World’s Leading Transfer Pricing Advisors and was named one of the Top 30 U.S. Tax Advisors). He is also in The Legal 500 Hall of Fame and is regularly recognized in the Law and Business Research’s International Who’s Who of Corporate and Tax Lawyers. David is listed in Chambers USA America's Leading Lawyers for Business, and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.



David is a lecturer at Stanford Law School and UC Berkeley Law School where he focuses on international taxation. He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.



 Speaking session 


Digitalisation, disputes and double taxation

Wednesday, May 19 - 13.45 - 14.35 BST

Brian Gleicher
Brian Gleicher
White & Case
Learn more ›
Brian Gleicher

partner, White & Case



TBC



 Speaking session 


Finding and implementing the shortest route to resolution

Thursday, May 20 - 14.55 - 15.45 BST

Mike Knobler
Mike Knobler
Fenwick & West
Learn more ›
Mike Knobler

associate, Fenwick & West


 

Michael concentrates his practice on a broad variety of tax matters.

 

During law school, Mike was an articles editor for the Yale Law Journal.

 

Prior to joining Fenwick, Mike was an associate in the Washington, D.C. office of a global law firm, where he worked on issues arising in all areas of the firm’s international corporate tax practice. He clerked for the Honorable Susan G. Braden at the U.S. Court of Federal Claims.

 

 

 Speaking session 

 

Digitalisation, disputes and double taxation

Wednesday, May 19 - 13.45 - 14.35 BST

Emmanuel Llinares
Emmanuel Llinares
NERA Consulting
Learn more ›
Emmanuel Llinares

head of global transfer pricing, NERA Consulting



Dr. Llinares is the Head of NERA’s Global Transfer Pricing Practice, based in Paris. He is an economist specializing in inter-company pricing, valuation, and intellectual property analyses. For twenty years, he has advised multinational companies on defining and implementing their intra-group pricing policies and has assisted them with design, documentation, and tax audit defense. Dr. Llinares also assists clients in the context of commercial or intellectual property-related litigation.



Dr. Llinares has managed intercompany pricing projects for multinationals in a wide range of industries, including transportation, energy, chemical, luxury goods, fashion, financial services, health care, real estate, media and entertainment, and food and beverage. He has also managed the economic analyses aspects of a large number of tax-related audits in Europe and other regions. He is considered by Euromoney to be one of the world's leading transfer pricing advisors.



Prior to joining NERA, Dr. Llinares was an economist with Arthur Andersen in London and with the KPMG Tax network in Paris. He is a former lecturer at the Economics Department of the University of Delaware and at the Ecole Supérieure de Gestion, a business school in Paris. Dr. Llinares has a PhD in economics from the University of Delaware and a doctorate in economics from the University of Lyon. He publishes frequently on the subject of transfer pricing and valuation.



 Speaking session 


Handling international tax disputes

Wednesday, May 19 - 12.35 - 13.25 BST

Niraja Srinivasan
Niraja Srinivasan
NERA Consulting
Learn more ›
Niraja Srinivasan

director, NERA Consulting



Dr. Niraja Srinivasan assists multinational companies and law firms with expert economic analysis and dispute resolution in transfer pricing for intellectual property and global supply chains. She has over 20 years of experience leading global transfer pricing strategy and risk mitigation for Fortune 50 companies in an extensive range of industries that include IT infrastructure manufacturing, software and digital services, consumer goods manufacturing and retail, energy services, and pharmaceutical/medical device manufacturing. Prior to joining NERA, Dr. Srinivasan was a Vice President in Dell Technologies’ Global Tax group.



Dr. Srinivasan has deep experience in identifying, implementing, and defending cashflow-generative transfer pricing policies and operational changes in the context of corporate restructuring, M&A planning, post-deal integration, and privatization. She has negotiated numerous Advance Pricing Agreements (APA) in Asia, Europe, and North America and secured favorable audit settlements while maintaining trustworthy business-tax administration relationships. She has created world-class transfer pricing models for a variety of intercompany financial transactions including cash pools, term loans, swaps, and financial and parent guarantees.



Dr. Srinivasan is an Adjunct Professor at Texas A&M University School of Law and the Vice-Chair of the American Bar Association Tax Section’s Transfer Pricing Committee. She received her PhD in economics and MA in public policy and management from The Wharton School of the University of Pennsylvania. She has published several articles on transfer pricing, taxation and ESG and is a frequent speaker at conferences.



 Speaking session 


Handling international tax disputes

Wednesday, May 19 - 12.35 - 13.25 BST

Samir Yahiaoui
Samir Yahiaoui
Deloitte
Learn more ›
Samir Yahiaoui

director, tax, Deloitte



Samir Yahiaoui is an International Tax director in Deloitte’s FTSE team. In recent years, he has been heavily involved in many in-depth tax investigations of specific domestic or international issues including transfer pricing and diverted profits tax, treasury related tax issues, and complex intangibles and capital gains matters. As a result, he has considerable experience of negotiating and dealing with HMRC at all levels. Samir also advises on the tax aspects of private and public mergers, acquisitions, disposals and joint ventures and on business and transaction structuring more generally. His clients are primarily complex multinationals groups, with a focus on UK listed groups in particular.


 Speaking session 


Managing tax disputes in uncertain times

Tuesday, May 18 - 13.20 - 14.10 BST

Darren Meredith
Darren Meredith
BP
Learn more ›
Darren Meredith

VP tax planning, BP



TBC


 Speaking session 


Managing tax disputes in uncertain times

Tuesday, May 18 - 13.20 - 14.10 BST

Carlos Enrech
Carlos Enrech
Ferrovial
Learn more ›
Carlos Enrech

head of tax UK&I, Ferrovial



Carlos Enrech is the head of tax of Ferrovial in the UK and Ireland. Ferrovial in the UK and Ireland represents a consolidated turnover of £4bn, 17,000 direct employees, total tax contribution in the UK of £400M, and it is a participant in UK critical projects and investments. Carlos is an attorney-at-law, qualified accountant and corporate tax adviser in the area of reorganizations, M&A, digital content and technology, international tax and sustainable infrastructure. He is a recognised in-house tax adviser and has contributed to the International Bar Association, American Bar Association and ITR over more than 25 years.



 Speaking session 


Digitalisation, disputes and double taxation

Wednesday, May 19 - 13.45 - 14.35 BST

Gerard Franklin
Gerard Franklin
Tishman Speyer
Learn more ›
Gerard Franklin

Managing Director – Tax, Accounting & Treasury, Tishman Speyer



TBC



 Speaking session 


Talking to the board about the risks of disputes

Thursday, May 20 - 13.45 - 14.35 BST

Catherine Harlow
Catherine Harlow
AstraZeneca
Learn more ›
Catherine Harlow

head of transfer pricing, AstraZeneca



TBC



 Speaking session 


Transfer pricing and related tax disputes activities

Tuesday, May 18 - 14.30 - 15.20 BST

Mark Houtzager
Mark Houtzager
Starbucks
Learn more ›
Mark Houtzager

EMEA tax leader, Starbucks



TBC


 Speaking session 


Managing tax disputes in uncertain times

Tuesday, May 18 - 13.20 - 14.10 BST

Giolla Kiely
Giolla Kiely
CDB Aviation
Learn more ›
Giolla Kiely

head of tax, CDB Aviation



TBC



 Speaking session 


Talking to the board about the risks of disputes

Thursday, May 20 - 13.45 - 14.35 BST

Donata Koren
Donata Koren
Zalando
Learn more ›
Donata Koren

global head of tax, Zalando



TBC



 Speaking session 


Digitalisation, disputes and double taxation

Wednesday, May 19 - 13.45 - 14.35 BST

Erik Knijnenburg
Erik Knijnenburg
H&M
Learn more ›
Erik Knijnenburg

global head of tax and TP, H&M


 

Before taking his current position as Head of Group Tax & Transfer Pricing, Erik was working as Country Manager for H&M in The Netherlands. His move from a commercial position in a country to the current central position has everything to do with the view central management has on the responsibilities and performances within the area of TP and taxation. The latter function is merely seen as a part of the total public affairs and CSR of The H&M Group.

 

 

The H&M Group embraces a pro-active attitude in the field of tax & TP and as a result Erik holds a wide experience in all procedures available to avoid or resolve disputes going public. Erik is based in Stockholm, Sweden.

 

 

 Speaking session 

 

Handling international tax disputes

Wednesday, May 19 - 12.35 - 13.25 BST

 

Finding and implementing the shortest route to resolution

Thursday, May 20 - 14.55 - 15.45 BST

Greg Leathes
Greg Leathes
LEGO Group
Learn more ›
Greg Leathes

Head of Tax EMEA, LEGO Group



TBC



 Speaking session 


Managing tax authority relationships

Thursday, May 20 - 12.35 - 13.25 BST

Don Maher
Don Maher
Mohawk Industries
Learn more ›
Don Maher

vice president taxes, Mohawk Industries



TBC



 Speaking session 


Transfer pricing and related tax disputes activities

Tuesday, May 18 - 14.30 - 15.20 BST

Massimo Mojana
Massimo Mojana
IMI Hydronic Engineering
Learn more ›
Massimo Mojana

head of tax, IMI Hydronic Engineering



TBC



 Speaking session 


Handling international tax disputes

Wednesday, May 19 - 12.35 - 13.25 BST

Parmesh Rajani
Parmesh Rajani
Kingfisher
Learn more ›
Parmesh Rajani

head of transfer pricing, Kingfisher



TBC



 Speaking session 


Managing tax authority relationships

Thursday, May 20 - 12.35 - 13.25 BST

Jose Olvera Salcedo
Jose Olvera Salcedo
Hitachi Europe
Learn more ›
Jose Olvera Salcedo

head of tax, Hitachi Europe



Jose is an International Tax specialist with more than 20 years of experience. He joined Hitachi Europe in 2015 where he is responsible for operational tax and transfer pricing matters, tax strategy, governance and risk management in the EMEA region. Before joining Hitachi, Jose worked at Harris Corporation as EMEA Tax Manager, looking after the company’s regional tax affairs. Prior to this, he worked for more than 11 years at PwC, based in Mexico City, Washington DC and London. During his time at PwC Jose advised companies in a wide range of business sectors. Jose holds a Bachelor’s degree in accounting, is a certified public accountant and has a Master’s Degree in Business Administration.



 Speaking session 


Talking to the board about the risks of disputes

Thursday, May 20 - 13.45 - 14.35 BST

Markus Schneider
Markus Schneider
Bayer
Learn more ›
Markus Schneider

global tax manager, group TP controversy, Bayer



TBC



 Speaking session 


Transfer pricing and related tax disputes activities

Tuesday, May 18 - 14.30 - 15.20 BST

Kamila Szydlowska
Kamila Szydlowska
Bausch Health Companies
Learn more ›
Kamila Szydlowska

senior tax director EMEA, Bausch Health Companies


 

TBC

 

 

 Speaking session 

 

Handling international tax disputes

Wednesday, May 19 - 12.35 - 13.25 BST

Josh White
Josh White
ITR
Learn more ›
Josh White

acting managing editor, ITR



Josh manages transfer pricing, BEPS, tax disputes and other direct tax matters for ITR's online and print audience. He covers a range of tax issues in these areas and how companies are dealing with them, as well as the influence of politics on tax developments.



 Speaking session 


Managing tax authority relationships

Thursday, May 20 - 12.35 - 13.25 BST

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TESTIMONIALS
"Very interactive sessions, lots of questions were addressed. Great topics were selected
"This was the first ITR conference that I have attended. I am impressed with the presentations and the interaction opportunities provided in a virtual environment
"One of the best online conferences I've experienced
"Very good sharing of practical advice and information. Far exceeded my expectation for a virtual tax event
"Very clear delivery of a timely topic from all the speakers -- pointed and focused coverage
"Very good variety of sessions. Technical, practical, soft skills all covered off

GOLD SPONSORS

Baker McKenzie
CMS
Deloitte
Fenwick
NERA Economic Consulting
White & Case

SILVER SPONSOR

DLAPiper
Skadden

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Email Gabriela Magaldo
+44 (0)20 7779 8837

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Email Jamil Ahad
+44 (0)20 7779 8767
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