Financial Transactions Within MNEs: Transfer Pricing at a Cross-road

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Intercompany financial transactions have received significant attention from tax authorities especially in the last few years.  Generally a very complex technical area that is often in the background, recent developments in controversy (starting with GE in Canada) as well as tax policy, e.g., BEPS Action 4, have projected this field of transfer pricing onto the main stage.  Often testing the boundaries of the arm's-length principle, recent transfer pricing disputes and policy developments have spawned neoteric phrases and concepts, such as implicit support and commercial rationality and “one capital structure, one rating, one rate”.  

With additional guidance from the BEPS project issued in late 2014 and further guidance expected in 2015, Russo and Moiz, both leading transfer pricing experts will:

• Provide an overview of the current regulatory environment, audit and controversy landscape
• Consider best practices in analyzing and benchmarking intercompany financial transactions
• Identify the key issues companies need to consider when designing and structuring a transfer pricing policy and conducting financial transactions in the current (and to be expected) environment

Educational Objectives:
• Review recent policy and regulatory developments and learn about some of the best practices for establishing and documenting intercompany financial transactions in the current environment. 
• Become conversant with the primary rules, opportunities and areas of risk as they relate to intercompany financial transactions on a global level. 
• Understand the economic methods that are regularly applied in pricing intercompany financial transactions and the benefits and limitations of applying such methods.  
• Understand the key issues that come up in transfer pricing audits of financial transactions and steps that can be taken to prepare for such audits. 

Who Should Attend this Event:
This program is intended for corporate tax directors, managers, controllers, and attorneys, as well as practicing CPAs and lawyers with clients having cross border intercompany financial transactions and other financial executives responsible for establishing and implementing intercompany credit policies, procedures, and pricing. No prerequisites / advanced preparation necessary. 



Antonio Russo is an established practitioner of international tax law. He is a partner with Baker & McKenzie Amsterdam’s award-winning Transfer Pricing Team and a member of the Global Transfer Pricing Steering Committee of Baker & McKenzie. A Fellow with the International Tax Center of the University of Leiden, Antonio lectures at numerous seminars and conferences around the world, as well as contributes articles to several international tax reviews. 

Antonio specializes in Transfer Pricing design, implementation and valuation of companies and intangible assets. He has extensive experience in tax planning/restructuring engagements, and has performed TP studies for clients in numerous industries. Antonio has also provided assistance to clients in developing strategies for the conclusion of APA’s as well as tax audit defense in EMEA, APAC, in North America and LATAM.


Moiz Shirazi is a Director Economist in the Chicago office of Baker & McKenzie. He focuses on transfer pricing and provides his clients with economic analyses and valuations that assist them in planning and supporting business reorganizations, as well as establishing and documenting global transfer prices. Mr. Shirazi has led economic analyses for a diverse set of clients from many different industries, including analyses on transfer pricing planning in the context of global restructuring, assistance in negotiating advance pricing agreements (APAs) with the IRS, intangible property valuation, preparing US and foreign transfer pricing documentation and transfer pricing controversy.

Mr. Shirazi focuses his practice on transfer pricing and valuation matters in relation to pricing of intercompany loans, cash pooling arrangements, guarantee fees, thin capitalization, stock option valuation, credit swaps, interest rate swaps, currency swaps, and other financial instruments. He has worked with some of the largest companies in the financial services industry to establish pricing for financial instruments, shared services arrangements, global trading and investment management operations, and revenue sharing in the context of client acquisition. Mr. Shirazi has also worked with some of the largest insurance companies in pricing for reinsurance transactions and remuneration for underwriting services.