20th anniversary

GLOBAL TRANSFER PRICING FORUM 2020

 
December 1 & 2

Agenda

  • Day one
  • Day two
8.20
REGISTRATION

8.50

OPENING COMMENTS

9.00

Keynote address: Navigating an uncertain transfer pricing landscape

 

The keynote presentation will look at the current transfer pricing landscape, and how practitioners can keep up with and prepare for key changes in an uncertain environment.

 

Speaker
Niraja Srinivasan, VP global transfer pricing, Dell

9.25

Transfer pricing implications of US Tax Reform

  • BEAT regulations
  • How to adapt your transfer pricing structure
  • How GILTI and FDDI impact transfer pricing arrangements
  • Has tax reform successfully addressed transfer pricing issues?

Speakers

Dara Kasouaher, director of transfer pricing, Mondelēz International
Dasantila Maksutaj, group tax director, Terumo Medical Corporation
Keith Brockman, VP global tax, Welbilt

10.15

Post-panel roundtable discussions


These roundtable discussions will provide the opportunity to debate with your peers about the key issues that emerged during the previous panel discussion on US Tax Reform.

10.30

COFFEE AND NETWORKING

11.00

Assessing the OECD’s ‘Unified Approach’

  • What are the benefits? What are the shortcomings?
  • How will the new nexus and profit allocation rules impact multinationals?
  • What measures can be taken to reduce the risk of double taxation?
  • How will disputes be resolved?

 

Speakers

Harlow Higinbotham. managing director, NERA
Niraja Srinivasan, VP global transfer pricing, Dell
Lorraine Eden, research professor of law and professor emerita of management, Texas A&M University
Nihan Mert-Beydilli, associate director – transfer pricing, NERA

12.00

Operational TP and digitalisation

  • Strategies for building an effective operational TP environment
  • What needs to change? Where should investment be directed?
  • How can existing systems be used to overcome data and process issues?
  • Finding the place for transfer pricing within your wider tax technology plan

Speakers

Nicole Williams, senior manager – global transfer pricing, Celanese

Pat Dervin, director of transfer pricing, Aon
George Stasny, manager – transfer pricing, Halliburton
Carmen White, director – tax technology, Microsoft

12.50

LUNCH AND NETWORKING

13.50

Transfer pricing of intangibles

  • Best practice for defining and valuing intangibles
  • Methods for establishing comparability

Speakers

Rick Cooper, vice president, Charles River Associates (moderator)

Azedine Assassi, global transfer pricing leader, GE

Kay Freund, director – global transfer pricing, Medtronic

Jeff Lonard, manager – transfer pricing, ITW
Sanford Stark, partner, Morgan Lewis

Ednaldo Silva, founder & director, RoyaltyStat

14.50

TP documentation and CbCR

  • Hear from multinationals on their experiences with documentation & CbCR
  • How is the collected data being used?
  • How to identify gaps in your CbCR filings that may be questioned by multiple tax authorities

Speakers

Yoshio Uehara, partner, Chevez Ruiz Zamarripa (moderator)

Amy Pinson, senior manager – transfer pricing, Bayer

Tosin Akande, senior vice president – transfer pricing, Citi

Jason Wiegand, associate director – global transfer pricing, Procter & Gamble

Sadia Nazir, director – global transfer pricing, Clarios

Oscar Campero, partner, Chevez Ruiz Zamarripa

15.50
COFFEE AND NETWORKING
16.20

Permanent establishments post-BEPS

  • Managing PE risk
  • Guidance on the attribution of profits to PEs
  • Challenges with taxing digital PEs

Speakers

Guglielmo Maisto, partner, Maisto e Associati

Aurelio Massimiano, partner, Maisto e Associati

16.50

Global transfer pricing developments: China, India and LATAM

  • Explore the latest developments in China, India and LATAM

  • How are multinationals managing relationships with tax authorities in these jurisdictions?

  • Assess regional responses to BEPS and what this means for your transfer pricing policy

Speakers

Abhishek Chawla, tax director, Xerox

David Garcia Morales, head of corporate tax, Geopark

Fernando Colucci, partner, Machado Meyer

17.40

CLOSING COMMENTS AND NETWORKING DRINKS RECEPTION

8.40
REGISTRATION

9.20

OPENING COMMENTS

9.30

Keynote address: The Arm’s Length Standard: David and the Three Goliaths


A review of the most recent transfer pricing cases

Speaker
Lorraine Eden, research professor of law and professor emerita of management, Texas A&M University

10.00

Financial transactions

  • What is the latest OECD guidance?
  • Explore the impact of the FTTP on treasury centres and how to deal with unintended consequences of TP rules
  • Understand the issues related to inter-company loans, guarantee transactions and cash pooling

Speakers

Joan Hortalà, partner, Cuatrecasas
Joy Harper, finance systems, integration and transformation, Google

10.50

COFFEE AND NETWORKING

11.20

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.

 

Roundtable A: The future of the arm’s-length principle

  • Discuss whether the arm’s-length principle will remain and, if so, how it will interact with new rules

 

Roundtable B: Transfer pricing risk-analysis post-BEPS

  • Assess whether BEPS has decreased risk appetite, and how to manage increasing transparency and scrutiny from tax authorities

 

Roundtable C: Managing an international audit

  • Debate best practices for managing an international audit

Speakers

Dave Thomsen, global transfer pricing, Keysight Technologies
Steve Allen, director – global transfer pricing, McDonald's Corporation

 

Roundtable D: Transfer pricing post-M&A

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

Speaker

Kay Freund, director - global transfer pricing, Medtronic

12.50

LUNCH AND NETWORKING

14.10

Dispute avoidance and resolution

  • Navigating disputes amid a changing controversy landscape
  • How to capitalise on recent initiatives on dispute prevention
  • Seeking certainty through APAs
  • Alternative dispute resolution

Speakers

Brian Gleicher, partner, White & Case
John Wall, APMA assistant director, IRS
Sonal Majmadur, adviser - global tax team, World Bank Group
Sue Huang, associate tax director - transfer pricing, Intel

15.00

CLOSING COMMENTS AND CLOSE OF FORUM

MIP International Women's Leadership Forum - London 2020

January 30, Waldorf Hilton Hotel, London

MIP International Patent Forum 2020

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

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MIP Global Trade Mark Forum 2020

March 10, Convene 810 Seventh Ave, New York

MIP US Patent Forum 2020

March 25 & 26, Convene 75 Rockefeller Plaza, New York

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Gold sponsors

Chevez Ruiz Zamarripa
Maisto e Associati
NERA Economic Consulting
White & Case

Silver sponsors

Charles River Associates
Cuatrecasas
Machado Meyer
Morgan Lewis
RoyaltyStat
Cuatrecasas
Machado Meyer
Morgan Lewis

Bronze sponsor

Knowledge partner

Association partner

Transportal
Bureau van Dijk
Chicago Tax Club