20th anniversary

GLOBAL TRANSFER PRICING FORUM EUROPE

September 2020

Amsterdam

Agenda

  • Day one
  • Day two
8.10
REGISTRATION

8.45

OPENING COMMENTS

Speaker
Anjana Haines, managing editor, International Tax Review

8.50

WELCOME ADDRESS

Speaker
Maik Heggmair, head of transfer pricing, WTS Global (Germany)

9.00

KEYNOTE ADDRESS

 

Review of the current transfer pricing landscape and the progress of implementation of recent OECD measures

Speakers

Manuel de los Santos Poveda, adviser - CTPA, OECD

9.30

Taxation of the digital economy

  • Assessing the scope of the OECD’s digital tax proposal
  • User participation, marketing intangibles and significant economic presence: understanding the alternative allocation of profits
  • How do we define marketing intangibles?
  • Are we moving beyond the arms-length principle?
10.30-10.45

Post-panel table discussions

10.45

COFFEE AND NETWORKING

11.15

Financial transactions: recent developments and future outlook

  • Hear an update on the OECD’s work on transfer pricing for financial transactions
  • Gain insight into the impact the FTTP has on treasury centres and how to deal with unintended consequences of TP rules
  • Understanding the issues related to inter-company loans, guarantee transactions and cash pooling

Speakers

Joan Hortalà Vallvé, partner, Cuatrecasas (moderator)
Andy Neuteleers, partner, T/A Economics, WTS Global (Belgium)
Daniel Ransom, transfer pricing director, GSK
Rogier Sterk, senior tax adviser, Loyens & Loeff
Joy Harper, head of treasury & tax, Google
Giacinto Valenti, head of transfer pricing, UniCredit

12.15

Post-BEPS supply chain modelling

  • Restructuring post-BEPS: strategies for adapting current supply chains
  • Modelling your supply chain to help manage risk, ensure compliance and increase tax value for your company
  • Managing conflicts presented by valuation rules as supply chains are restructured

Speakers

David Forst, partner, Fenwick & West (moderator)
Önder Albayrak, deputy head of global transfer pricing, Sanofi
Parmesh Rajani
, head of transfer pricing, Kingfisher
Axel Nientimp
, partner, WTS Global (Germany)
Marta Pankiv
, director of tax, Tricentis

13.05

LUNCH AND NETWORKING

14.00

Operational TP and digitalisation

  • Building an effective operational TP environment – what needs to change? Where should investment be directed?
  • Utilising existing systems and new tools to overcome data and process issues
  • Strategies for developing a group-wide strategy on tax-tech and finding the place for transfer pricing within this

Speakers

Raymund Gerardu, managing partner, TPA Global (moderator)
Olivier Noel, head of global transfer pricing, Avnet
Isabel Karl
, operational transfer pricing, Deutsche Bank
Katarina Petovska
, global senior transfer pricing manager, Dell
Andreas Riedl
, partner, WTS Global (Germany)
Gyorgy Ahmann
, transfer pricing manager – operations, Diageo

14.50

Risk assessment: ICAP 2.0

  • Assessing the outcome of the ICAP pilot programme and the latest improvements
  • Tips for working towards a more cooperative compliance model
  • Moving ICAP forward – the role of government bodies, tax authorities and corporations

Speakers

Ruth Steedman, partner, FTI Consulting, WTS Global (UK) (moderator)

Mark Johnson, head of unit, tax dispute prevention/CbC reporting, OECD

Rocio Bermudez, transfer pricing & tax global practices senior manager, Repso

Maria Teresa Ruiz de Azua, global transfer pricing manager, Procter & Gamble

15.40
COFFEE AND NETWORKING
16.10

Global perspectives on transfer pricing issues: China, India and LATAM

  • Explore the latest transfer pricing developments in China, India and LATAM
  • Hear from multinationals on how they’re managing their relationships with different tax authorities in these regions
  • Assess how these regions are responding to BEPS and what this means for your TP policy

Speakers

Kathrin Zoeller, head of global transfer pricing, Weatherford (moderator)

Raffaele Petruzzi, managing director, WU Transfer Pricing Centre

Avni Dika, head of global transfer pricing, Syngenta

Sam Sim, head of transfer pricing Asia Pacific, WTS Global (Singapore)

Andrea Grainger, head of transfer pricing, Swiss RE

Clark Armitage, member – transfer pricing and international tax, Caplin & Drysdale

17.00

CLOSING COMMENTS

Speaker

Josh White, deputy editor, International Tax Review

17.10

DRINKS RECEPTION

8.45
REGISTRATION

9.20

OPENING COMMENTS

Speaker

Anjana Haines, managing editor, International Tax Review

9.30

Profit-split method

  • Hear the latest OECD guidance
  • Discuss practical applications

Speakers

Josh White, deputy editor, International Tax Review (moderator)
Martin Lagarden, head of global transfer pricing, Henkel
Manuel de los Santos Poveda
, adviser – CTPA, OECD
Bodo Roglmeier
, head of international tax and tax compliance, UniCredit

10.20

Global perspectives on transfer pricing issues: Germany, UK, Russia and Japan

  • Explore the latest transfer pricing developments in these regions
  • Hear from multinationals on how they’re managing their relationships with different tax authorities
  • Assess how these regions are responding to BEPS and what this means for your TP policy

Speakers

Brian Gleicher, partner, White & Case (moderator)
Enrique Guzman, transfer pricing specialist, Hitachi Europe
Alistair Wadey
, senior tax director – transfer pricing, PepsiCo
John Willows
, transfer pricing manager, Wyelands Capital
Bodo Bender
, partner, White & Case

11.10

COFFEE AND NETWORKING

11.40

Roundtable discussions

These interactive roundtable discussions will provide a unique opportunity to work closely with your peers to develop strategies for managing important transfer pricing issues. Discussions will be followed by a presentation of key findings by the roundtable chairs

 

Roundtable A: Transfer pricing risk analysis post-BEPS

  • Has BEPS decreased risk appetite? How do you manage increasing transparency and scrutiny from authorities?

Speaker

Gian Luca Nieddhu, head of transfer pricing, Hager & Partners
Dietmar Huber
, manager partner, Hager & Partners

 

Roundtable B: TP documentation and CbCR

  • Discuss practical experiences with Country by Country Reporting and find out how tax authorities have been responding

Speaker

Brian Gleicher, partner, White & Case

 

Roundtable C: US tax reform: a new TP landscape

 

  • Assess post-legislation developments – what have the practical implications been and how have companies successfully adapted?

Speaker

Lucia Fedina, head of global transfer pricing, CBRE

 

Roundtable D: Guidance on the transfer pricing of intangibles

  • Debate best practices for identifying and valuing intangibles and share methods for establishing comparability

Speaker

Robert Hartley, partner, Mishcon de Reya

 

Roundtable E: TP documentation and CbCR

  • Discuss practical experiences with Country by Country Reporting and find out how tax authorities have been responding

Speaker

Frank Groffi, group tax counsel – transfer pricing and business models, Nestlé

 

Roundtable F: US tax reform: a new TP landscape

  • Assess post-legislation developments – what have the practical implications been and how have companies successfully adapted?

Speaker

Kathrin Zoeller, head of global transfer pricing, Weatherford

 

Roundtable G: Guidance on the transfer pricing of intangibles

  • Debate best practices for identifying and valuing intangibles and share methods for establishing comparability

Speaker

Gary Richards, partner, Mishcon de Reya

 

Roundtable H: Transfer pricing post-M&A

  • Assess the challenges of implementing TP processes, policies and arrangements in a post-merger/acquisition environment

Speaker

John Willows, transfer pricing manager, Wyelands Capital

 

Roundtable I: The future of the arms-length principle

  • Discuss whether the arms-length principle should remain and, if so, how?

Speaker

Eduardo Floering, head of transfer pricing, Muller Group

 

Roundtable J: Managing an on-site audit

  • Debate with your peers best practices for managing an on-site audit

Speaker

Rocio Bermudez, transfer pricing & tax global practices senior manager, Repsol

 

Roundtable K: Interpreting DAC6

  • Share insights into how to overcome increased compliance challenges and discuss how different countries are interpreting DAC6 and what this means for you

Speaker

Roxana Popel, head of tax, CMS Romania

13.10

LUNCH AND NETWORKING

14.10

Top tips for successful dispute resolution

  • Practical guidance for avoiding and resolving disputes
  • Assessing recent initiatives on dispute prevention
  • Strategies for developing a large network of APAs

Speakers

Xavier Daluzeau, partner, CMS France (moderator)
Marlies Vermeulen, managing director – global transfer pricing, Applied Materials
Markus Schneider, transfer pricing manager, Bayer
Bartłomiej Wajda, counsel, CMS Poland
Christian Runge, global head of transfer pricing and tax technology, Shell

15.00

KEYNOTE ADDRESS

Speaker

Jared Walls, partner, Valentiam, WTS Global (US)

15.30

CLOSING COMMENTS

Speaker

Josh White, deputy editor, International Tax Review

15.00

CLOSE OF CONFERENCE

MIP International Women's Leadership Forum - London 2020

January 30, Waldorf Hilton Hotel, London

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March 4 & 5, etc. venues St Paul's, London

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In association with

WTS Global

Gold Sponsors

CMS
Hager & Partners
Mishcon de Reya
White & case logo

Silver Sponsors

Caplin & Drysdale
Cuatrecasas
Fenwick & West logo
Loyens & Loeff
Skatt
TPA Global

Bronze Sponsor

Bureau Van Dijk