Educational Course Credit — Up to 14 CPE / CLE Credits Available
Agenda
Monday, March 31st
9:15am - 9:45am Keynote Address: Update on the OECD Base Erosion and Profit Shifting Action Plan and Other OECD Projects
Speaker: Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration, OECD
9:45am - 11:30am Intangibles: New OECD Guidance
Moderator: Caroline Silberztein, Baker & McKenzie, France
Panellists: Joseph Andrus, Head of Transfer Pricing Unit, OECD; Michael McDonald, Financial Economist, US Department of Treasury; Gary Sprague, Baker & McKenzie, US
11:30am - 11:45am Refreshments
11:45am - 1:00pm How to Balance Functions, Assets, Capital Provision and Risk Bearing in Transfer Pricing Analysis.
Panellists: Michelle Levac, Transfer Pricing Specialist, Canada Revenue Authority, Chair of OECD Working Party No. 6
Through case studies, panellists will discuss the importance of people functions in transfer pricing and economic substance assessments. Can risk bearing and rights to intangible related return be separated from people functions? What is economic substance in transfer pricing? Are the lines moving in relation to respect for contracts and recharacterisation of transactions? Is there still an accepted line between transfer pricing and attributing profits to permanent establishments?
1:00pm - 1:45pm LUNCH
1:45pm - 2:15pm Keynote Address: Key Challenges and Trends in Transfer Pricing: a Perspective from the United States
2:15pm - 4:00pm Post-Acquisition Integration
Panellists: Michael McDonald, Financial Economist, US Department of Treasury
This panel will address key transfer pricing questions which arise in post-acquisition integration, including restructuring of IP ownership and supply chain, IP valuation issues, the notion of goodwill and the potential relevance (or not) for transfer pricing purposes of purchase price allocations and the notion of compensable clientele in intragroup settings.
4:00pm - 4:15pm Refreshments
4:15pm - 6:00pm Views from Emerging and Developing Economies
Moderator: Carol Dunahoo, Baker & McKenzie, US
This panel will address the latest developments and foreseeable trends in key non-OECD economies and at the United Nations.
Tuesday, April 1st
9:00am - 10:45am The Era Of Transparency
Moderator: Mary Bennett, Baker & McKenzie, US
This panel will address a series of practical questions which arise for taxpayers in the increased focus on transparency in the transfer pricing area: exchange of information among tax administrations, compulsory disclosure, global value chain disclosure requirements, country-by-country reporting, search & seizure procedures, parliamentary hearings, voluntary disclosure. How do companies collect, organize and control information?
10:45am - 11:00am Refreshments
11:00am - 12:45am Preventing and Eliminating Double Taxation: Does it Work?
Moderator: Richard Fletcher, Baker & McKenzie, UK
Panellists: Sandra Knaepen, General Administration of Taxes International Relations, Belgium
This panel will provide practical insight into what works and what does not work in terms of prevention and elimination of double taxation. It will cover in particular multilateral, joint or simultaneous audits; advance pricing agreements; mutual agreement procedures and arbitration; alternative dispute resolution mechanisms such as mediation, highlighting differences of practices from a range of countries.
12:45am - 1:30pm Lunch
1:30pm - 2:00pm Keynote Address: Arm's Length Principle or Common Corporate Consolidated Tax Base ? The European Commission Perspective (including an update on the work of the EU Joint Transfer Pricing Forum)
2:00pm - 3:15pm Managing a Global Transfer Pricing Project : Success Factors and Pitfalls
3:15pm - 4:30pm BLOOMBERG BNA’S TRANSFER PRICING FORUM – IMPORTANT CASE LAW DEVELOPMENTS
4:30pm - 4:45pm Refreshments
4:45pm - 5:15pm Questions & Answers