Join us April 12 and 13 in Paris for the 6th Annual Bloomberg Tax and Baker McKenzie Global Transfer Pricing Conference. The Global Transfer Pricing Conference Series brings together top government and regulatory officials, senior practitioners from large multinational corporations, and some of the best transfer pricing professionals in the business.
Over the course of two days you’ll learn about the European Union and OECD tax policy agendas for 2018, the implications of U.S. tax reform for non U.S. multi-national corporations, the new OECD discussion drafts on profit splits and attributing profit to permanent establishments, and taxation of the digital economy.
You will have the opportunity to hear from key government officials from around the world.
Attendees will also engage with corporate representatives as they share the lessons learned resulting from filing their first country-by-country reports and their insight on the future implications of BEPS Action 13.
Thursday, 12 April 2018
8:30 AM – 5:00 PM
Networking reception to follow.
Friday, 13 April 2018
8:15 AM – 2:30 PM
The Westin Paris – Vendôme
3 Rue de Castiglione
Paris 75001 France
8:30 AM Breakfast and Registration
9:15 AM Keynote Address – Transfer Pricing Audits: Roundup of International Transfer Pricing Disputes and Case Law
Jonathan Peacock QC, Queen's Counsel, 11 New Square
10:00 AM Working Party No. 6: Critical Updates for 2018
The panel will provide critical updates from Working Party No. 6 on recent and ongoing initiatives, including the work on profit splits and attribution of profits to permanent establishments (BEPS Action 7).
Moderator: Mary Bennett, Partner, Baker McKenzie, Washington
11:30 AM Break
12:00 PM Transfer Pricing Documentation and Country-by-Country Reporting (BEPS Action 13): One Year In
One year into implementation of country-by-country (CbC) reporting, master file, and local file documentation requirements, what are the lessons learned? In this session we’ll hear from both corporate and government perspectives on the challenges and opportunities of Action 13. Have the intended efficiencies for governments and multinational corporations been achieved, or has it become an added compliance and administrative burden? We’ll also share top insights from the OECD Forum on Tax Administration’s handbook on Effective Tax Risk Assessment which provides detailed guidance for tax administrations to use CbCR and other information to perform risk assessment.
Moderator: Margreet Nijhof, Partner, Baker McKenzie, Amsterdam
1:00 PM Lunch
2:00 PM Keynote Address – The EU Tax Agenda
Stephen Quest, Director General for Taxation and Customs Union, European Commission
2:30 PM Transfer Pricing and Developing Countries: Key Updates and Insights
In recent years, emerging and developing economies have become far more active in the transfer pricing landscape, with the release of the UN Manual on Transfer Pricing, the participation of non-OECD economies in the BEPS project, and some strong views expressed in domestic regulations and audits. In parallel, efforts have been made at the United Nations and OECD to make transfer pricing guidance relevant for all countries, including those with limited audit resources and limited access to the comparable data. In this session, we:
Moderator: Sanjiv Malhotra, Director of Economics, Baker McKenzie, Singapore
3:30 PM Break
4:00 PM Taxation of the Digital Economy for Digital and Non-Digital Companies
Addressing key challenges of digital economy taxation is a top priority for both the OECD and EU, with the OECD planning to release a further BEPS Action 1 report in early 2018 and the European Commission launching an ambitious EU agenda to “influence the international discussions and develop meaningful solutions to taxing the digital economy,” with the goal of reaching international agreement on guidelines by spring 2018. Commentators and practitioners however recognized that there is no ring fencing of the digital economy and that most businesses today are going digital to at least some extent, including the traditional brick-and-mortar businesses.
In this session, we’ll examine what these developments could mean for businesses operating in the digital economy, as well as the new challenges and opportunities for non-digital companies going digital.
Moderator: Richard Fletcher, Principal Tax Advisor, Baker McKenzie, London
5:00 PM Networking Reception
8:15 AM Breakfast
9:00 AM Keynote – 2018 Outlook: A View from the OECD
Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, OECD
9:30 AM U.S. Tax Reform: Transfer Pricing Implications for Non-U.S. Multinationals
With the Tax Cuts and Jobs Act, the U.S. has enacted very ambitious and deep tax reform. The decreasing corporate income tax rate and new rules on tax loss carry-overs will impact many groups’ deferred tax positions. The transition to a territorial system is accompanied by new incentives for U.S. multinationals to repatriate cash, and new rules for the taxation of U.S.-held CFCs (global intangible low-taxed income, or GILTI) and the favorable taxation of distant sales by U.S. companies (foreign-derived intangible income, or FDII). This could all be a game-changer, not only for U.S. multinational corporations, but also for non-U.S. ones with operations in the U.S. The latter entities will need to factor all the above considerations plus the new BEAT (base erosion anti-avoidance tax) in their U.S. transfer pricing planning. Finally, new rules on interest deduction and hybrids will affect cross-border loans and licensing to the U.S. This panel will provide an overview of the most salient points that non-U.S. multinationals should be aware of.
Moderator: Caroline Silberztein, Partner, Baker McKenzie, Paris
11:00 AM Break
11:30 AM The Future of Audits and Advance Pricing Agreements
As new guidance is issued and audit activities are increasing, panelists will provide updates on the following:
Moderator: Antonio Russo, Partner, Baker McKenzie, Amsterdam
12:30 PM Financial Transactions: New Constraints and Unresolved Issues
Moderator: Steve Labrum, Principal Tax Advisor, Baker McKenzie, London
1:30 PM Lunch
2:30 PM Conference Concludes
Mary Bennett is a partner in Baker McKenzie’s Tax Practice Group, where she advises both U.S. and foreign-based companies on tax policy issues and assists them with international tax planning and controversy matters. She is the Chair of the Firm’s Global Tax Policy Group. Mary has more than 35 years of international tax experience, including having served from 2005 to 2011 as Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the OECD’s Centre for Tax Policy & Administration in Paris and earlier in her career as the Deputy International Tax Counsel of the U.S. Treasury Department. She has been recognized as one of America’s leading tax lawyers by Chambers USA, The International Who’s Who of Corporate Tax Lawyers, and Euromoney’s Guide to Women in Business Law and Guide to the World’s Leading Tax Advisers. She is a graduate of Harvard University and Columbia Law School and holds a master of laws degree in taxation from Boston University Law School.
Melinda Brown is a senior transfer pricing advisor at the OECD’s Centre for Tax Policy and Administration. She was heavily involved in the development of transfer pricing guidance under the BEPS Action Plan and now takes a leading role in the post-BEPS transfer pricing work at the OECD. Melinda also works closely with non-OECD economies, and is a member of the UN Subcommittee on Transfer Pricing. In 2016, Melinda took over the OECD leadership of the international tax Toolkits for low-income countries, a joint initiative of the OECD, IMF, World Bank Group and UN. Before joining the OECD, Melinda was a senior transfer pricing specialist and competent authority at the Australian Taxation Office; and in 2011-2012 was seconded to the Australian Treasury to work on transfer pricing law reform.
Matteo Crispi is the Head of Global International Tax and Transfer Pricing at Barilla where he is responsible for the global TP activities within the all Group, leading major TP projects, centralized TP Compliance, audits and APAs. Prior to this, Matteo was Europe Tax Manager at Barilla and Senior Advisor at Ernst & Young in the international tax service line. He has more than ten years of experience including management of tax audits and negotiation of APAs with tax authorities, business restructuring and M&As, development of tax control framework within cooperative compliance program. Matteo has an LL.M. from Leiden University, he is Chartered Accountant and Auditor and has a degree in Economics.
Richard Fletcher heads the UK Transfer Pricing Group in London. A seasoned professional with over 30 years of experience as an international tax adviser, he has published a number of articles in various tax technical journals. Richard has presented at the International Tax Review’s Global Transfer Pricing Conference for a number of years and at meetings of tax directors of UK multinationals for the UK branch of the International Fiscal Association.
Catherine has 20 years’ experience of advising on transfer pricing matters both in industry and in practice. She has been Head of Transfer Pricing at AstraZeneca since September 2017 where she has global responsibility for all aspects of AstraZeneca’s transfer pricing matters including planning, managing and defending their transfer pricing arrangements.
Prior to this, Catherine was Head of Transfer Pricing for the RELX group for 10 years where she managed a multinational team and led negotiations with tax authorities on transfer pricing matters including APAs. She is a regular speaker at transfer pricing conferences and at the OECD where she most recently represented AstraZeneca in the Consultation on Profit Splits.
Catherine trained as a Chartered Accountant and a Chartered Tax Advisor with Ernst and Young and has a degree in Philosophy, Politics and Economics (PPE) from Oxford University.
Jacky is the founder and managing partner of JH & Co., an Israeli law firm that provides a full range of transfer pricing and related international tax services. Jacky has over 18 years of experience advising on international tax, transfer pricing, IP valuations and supply chain optimization, mostly as a senior partner at a Big 4 accounting firm. He is the author of “Transfer Pricing”, the first comprehensive Hebrew book on transfer pricing and has published articles in leading Israeli professional publications. Euromoney and the International Tax Review have consistently listed Jacky as a leading practitioner in the field. Jacky holds an LL.M. degree in International Taxation (Cum Laude) from the University of Leiden and is a member of the Israeli and NY State bar associations.
Julie is a former director in the transfer pricing practice of Deloitte Tax LLP, most recently managing the Carolinas transfer pricing practice. She has extensive experience assisting clients with international and multistate projects involving transfer pricing planning, documentation, and audit defense. Julie has 25 years of public accounting experience, of which 18 were devoted exclusively to transfer pricing.
Julie received her BBA Accounting from the University of Wisconsin-Eau Claire and her MST Taxation from American University.
Jukka Karjalainen is a member of the UK Transfer Pricing Group in London and the Tax Leader for the Business Transformations Practice. Jukka has 20 years of experience dealing with transfer pricing and international corporate tax issues. He has experience working in several jurisdictions, namely the UK, Finland and Australia. Jukka has published a number of articles on transfer pricing and tax aligned supply chain and is the co-author of the first ever comprehensive Finnish book on transfer pricing “Siirtohinnoittelu”. He has been listed amongst the leading practitioners in his field by the Euromoney surveys and the International Tax Review.
Tatjana leads the EMEA transfer pricing practice of Whirlpool Corporation. Prior to this she had been a transfer pricing advisor for 15 years primarily practicing in EMEA and APAC. Her expertise covers the full range starting from designing transfer pricing systems through implementation and compliance to leading transfer pricing controversies.
Steve Labrum joined Baker McKenzie's transfer pricing practice in 2016. He has twenty years of experience working for Big Four accounting firms, including seventeen years as a partner and as Global Head of Financial Services Transfer Pricing. Steve has also worked in the banking industry for five years. Steve’s practice covers transfer pricing policy design, business restructuring, global documentation, and controversy with tax authorities. His primary industry focus is financial services, including the full spectrum of banking, investment management and insurance clients. Steve also has considerable experience in the areas of intangibles and commercial risks, and has worked with a range of clients across a number of industries. He has also worked extensively on transfer pricing engagements for the corporate treasuries of multinationals, where his knowledge of financial markets has been critical to addressing clients' needs.
Sanjiv Malhotra has extensive experience in India tax and transfer pricing matters and has been advising several Fortune 500 multinationals on a range of tax structuring, transfer pricing and cross-border dispute resolution matters. Mr. Malhotra regularly participates in national and international discussions on policy aspects of transfer pricing. He has had articles published in the Bureau of National Affairs (BNA), International Taxation, International Fiscal Association and Euromoney. He also regularly speaks in national and international seminars in relation to transfer pricing and international tax matters including those organized by BNA Bloomberg, Tax Executives Institute, International Tax Review, among others. Mr. Malhotra has worked on numerous global and regional assignments and has represented many multinational corporations during their transfer pricing audits and litigation in India. His core competencies lie in transfer pricing planning and dispute resolution, and he has been working on many Competent Authority and APA negotiations.
Sri Nagarajan is a Director in Baker McKenzie's economics consulting practice and has over 15 years of experience in transfer pricing consulting and industry. She joined Baker McKenzie's tax practise in Silicon Valley in 2003 and advises multinational companies on various aspects of transfer pricing for tangible goods, intangibles and services including planning, restructuring, compliance/documentation, advance pricing agreements and audits. A particular focus of her practice has been the structuring of intercompany transactions involving transfers and valuation of intangible property.
Ms. Nagarajan is a member of Baker McKenzie's North America Transfer Pricing Steering Committee, contributor/editor for the Baker & McKenzie Transfer Pricing handbook and a frequent speaker at tax conferences.
Margreet Nijhof is a partner in Baker McKenzie’s award-wining Amsterdam Transfer Pricing Team and chairs the Amsterdam Tax Practice. Margreet specializes in international tax advice for multinationals with a focus on international transfer pricing in the broadest sense, including, (multi-jurisdictional) transfer pricing planning, documentation, support and defense. Margreet has close to 20 years of experience on both sides of the Atlantic and has a dual qualification: she is admitted to the bar in California (1997) and is also a qualified Dutch Tax Advisor. Before joining Baker McKenzie Amsterdam in 2008, she worked as US tax lawyer at Baker McKenzie San Francisco for more than 10 years. Margreet Nijhof was awarded ‘Best in Transfer Pricing’ at Euromoney’s EMEA Women in Business Law Awards in both 2014 and 2015.
Michael Nixon is an economist with 16 years’ experience in transfer pricing consulting and academia. His experience includes transfer pricing and business restructuring projects in the UK, Germany, the Netherlands and Singapore, where he has been based for the last six years. He is a member of the Singapore Transfer Pricing consultation group with the Inland Revenue Authority of Singapore (IRAS), and has undertaken training for the IRAS Tax Academy. He also consults with Singapore academic institutions on transfer pricing and business restructuring matters.
Joshua D. Odintz is a partner in Baker McKenzie’s North American Tax Practice Group and is the managing partner of Baker McKenzie's Washington Tax Department. Joshua held high-level government positions with both the US Department of the Treasury and the Senate Finance Committee. He previously served as a Senior Advisor for Tax Reform to the Assistant Secretary at the US Department of the Treasury, where he advised Senior Treasury officials on tax reform options and issues. Joshua also served as the Chief Tax Counsel to the President’s National Commission on Fiscal Responsibility and Reform, and was instrumental in formulating the tax proposals that were contained in the Commission’s report, entitled the Moment of Truth. Additionally, Joshua served as the Acting Tax Legislative Counsel at the Treasury.
Joshua is a frequent speaker at ABA Tax Section, NY State Bar Tax Section, Practicing Law Institute and Federal Bar Association tax meetings and conferences.
Jonathan Peacock QC is a tax barrister based in London with over 30 years’ experience of UK and international tax issues. He has a broad tax practice, advising both corporate and individual taxpayers on direct and indirect tax matters. He is a leading tax advocate in the UK and regularly appears in the appellate courts in the most significant tax cases in the UK Court of Appeal, the UK Supreme Court and the Court of Justice of the European Union. He has acted both for and against the UK Government in important “tax avoidance” cases.
He advises on all the different types of taxes levied in the UK and quite a few levied in other countries around the world.
Jonathan has led seminars on the Oxford University BCL and Master in Law and Finance courses, is a member of the External Faculty for the new Oxford MSc in Taxation course and is the author of numerous articles and several books on aspects of revenue law.
He was Chairman of the Revenue Bar Association (2013-2016) and is member of the Bar Council, International Committee and of the Conseil des Barreaux Européens (“CCBE”) Tax Committee.
Stephen Quest is the Director-General for Taxation and Customs Union at the European Commission. Stephen joined the European Commission in 1993. Since then he has held a number of positions across different policy areas, including Financial Programming and Budget of the European Union, Environment, and Employment and Social Affairs. Most recently he held the positons of Director-General for Informatics, the Commission's department providing digital solutions to enable European policies and support the Commission's internal administration; and Director of the Office that administers and pays the Individual financial entitlements of the staff of the European Commission. Prior to joining the European Commission, Stephen worked for the UK Department of Employment and the UK Permanent Representation to the European Union. He graduated in 1986 from the University of York, obtaining a degree in History.
Irene Ros is the Global Transfer Pricing Manager at Shell International B.V. where she is responsible for principles, best practices and guidance for the global TP activities in Shell, leading major TP projects and supporting country teams and the centralised TP Compliance team in documentation and audits/MAP’s/APA’s for TP matters. She started her career working for the Dutch Tax Authorities as a corporate income tax inspector and at the Ministery of Finance in policy. In 2000 she joined Shell, starting in the Dutch tax team and successively working in various parts of the tax department: Holdings & Treasury, M&A, leading the Dutch tax team. In 2017, Irene became the Global Transfer Pricing Manager. She is based in The Hague.
Sylvie Roucart is a senior tax adviser at Total. She specializes in international taxation and is more specifically in charge of the upstream, midstream and downstream tax matters of the group in Northern America and Western Africa.
She joined Total in 2011, after a 10 year experience in law firms. She spent 3 years in New York between 2007 and 2009 doing M&A and advising MNGs on their inbound transactions.
Antonio Russo is an established practitioner of international tax law. He is a partner (Economist & Tax Advisor) with Baker McKenzie Amsterdam’s award-winning Transfer Pricing Team. Antonio specializes in transfer pricing design, implementation and valuation of companies and intangible assets. He lectures a numerous seminars, conferences and universities around the world. Antonio Russo is listed as a leading individual in Tax by Legal 500.
Pascal Saint-Amans took on his duties as Director of the Center for Tax Policy and Administration at the OECD on 1 February 2012. Mr. Saint-Amans, a French national, joined the OECD in September 2007 as Head of the International Co-operation and Tax Competition Division in the CTPA. He played a key role in the advancement of the OECD tax transparency agenda in the context of the G20. In October 2009 he was appointed Head of the Global Forum Division, created to service the Global Forum on Transparency and Exchange of Information for Tax Purposes, a programme with the participation of over 100 countries.
Arnaud Sage heads the French Department in charge of prevention and resolution of transfer pricing disputes since 2015. He has over 20 years of experience in international tax matters within the French tax administration, including 10 years in the French APA program and 5 years as a competent authority dealing with mutual agreement procedures. Mr. Sage is also the French Delegate at the OECD FTA MAP Forum and at the Sub-group MCAA (Model Competent authority agreement, BEPS Action 15).
Dr. Stephan Schnorberger helps businesses on the tax challenges of running or changing their international supply chain. He devotes his experience in international tax, transfer pricing and business restructuring to solve issues in tax planning, audit defense, APAs and disputes with tax authorities. He also works heavily in valuations and regulatory economics. Stephan has for numerous years been recognized in the Euromoney Expert Guide survey among "The Best of the Best" Global Tax Advisors and Global Transfer Pricing Advisors. Stephan represents and works with clients on solving issues in transfer pricing, international tax planning and optimization of business change, and competition economics.
Carlos Pérez Gómez Serrano is Director of Transfer Pricing in the Tax Administration Service (Ministry of Finance In Mexico). He has a degree in Economics from Universidad Iberoamericana and a Master in Valuation. He has participated as exponent and instructor in Transfer Pricing Forums and courses to foreign governments, as the Mexican Delegate in the Working Party 6 (WP6) in the Organization for Economic Co-operation and Development (OECD), included the “Base Erosion and Profit Shifting” Project (BEPS), and as a member of the United Nations Subcommittee on Transfer Pricing.
Caroline Silberztein heads Baker McKenzie’s French Transfer Pricing and International Tax Practice. She advises a range of multinational enterprises with risk assessment, design and implementation of new transfer pricing policies, audits and dispute prevention and resolution. She is nominated by France on the list of independent persons of standing authorized to serve as arbitrators for the application of the European Arbitration Convention. Prior to joining the Firm in September 2011, she headed the OECD Transfer Pricing Unit from 2001 to 2011 and led the 2010 update of the OECD Transfer Pricing Guidelines. She has been an observer to the EU Joint Transfer Pricing Forum from its inception until 2011. A member of the United Nations Sub-Committee on Transfer Pricing, she continues to be involved in policy dialogue with OECD and non-OECD countries. Ms. Silberztein is a visiting professor in several European universities.
Stig Sollund has a Law degree from University of Oslo 1975. Has held various positions at the Norwegian Ministry of Finance since 1980 where his areas of work have included legislation on business taxation, special tax regimes for petroleum production, hydro power and shipping, transfer pricing and tax treaties. His present position is director general for international tax at the Tax Law Department. Mr. Sollund is delegate to the OECD Committee on Fiscal Affairs and Member of its Bureau and the Steering Group of the Inclusive Framework on BEPS, as well as delegate to Working Party no 6 and member of its Bureau. He was a member of the United Nations Committee of Experts on International Cooperation in Tax Matters for the years 2005-2017 and coordinator of its Subcommittee on Transfer Pricing that developed the UN Practical Transfer Pricing Manual for developing countries, and now serving as co-coordinator of the subcommittee keeping the Manual updated. He has also served as deputy judge and practiced tax law in the private sector, most recently as partner of Bugge, Arentz-Hansen and Rasmussen (BA-HR) law firm, Oslo.
Gary D. Sprague a 25-year veteran of international law and managing partner in Baker McKenzie’s San Francisco/Palo Alto office, focuses his practice on international corporate tax planning and advice, tax controversies and e-commerce law, and represents software, high technology, and e-commerce companies. Mr. Sprague is a recognized leader in his field by Bay Area Lawyer Magazine, Best Lawyers in America, Northern California Super Lawyers, and Who's Who Legal and Guide to The World's Leading Tax Advisers. He is also regularly included among the North America's top tax advisers, most recently by the International Tax Review World Tax2011, and is a regular contributor to the Tax Management International Journal’s Leading Practitioner Commentary.
Jefferson VanderWolk is the head of the Tax Treaty, Transfer Pricing, and Financial Transactions Division at the OECD Centre for Tax Policy and Administration. He is a lawyer who has been engaged in international tax practice, policy development, and scholarship since 1985. He has been a partner at Baker & McKenzie and Deloitte in both London and Hong Kong, a corporate tax director at Merrill Lynch, a Special Counsel at the IRS Office of Chief Counsel, a law professor in Hong Kong, London, and Washington DC, and International Tax Counsel to the U.S. Senate Committee on Finance. Before joining the OECD in July 2016, he was with Washington Council EY in Washington DC. He has published extensively on tax law subjects and participates in numerous professional organizations. He became a Fellow of the Chartered Institute of Taxation in 2004, serves on the Academic Committee for the CIOT’s Advanced Diploma in International Taxation, and is a Distinguished Fellow of the Chinese University of Hong Kong’s Faculty of Law. He is admitted to practice in both the U.S. and the U.K. and is a citizen of both countries.
Antonio A. Weffer is a tax director in Baker McKenzie's Tax Practice Group and the head of the Firm's transfer pricing practice in Luxembourg. Mr. Weffer is an active member of several international professional tax organizations, and regularly publishes articles on international tax issues and speaks at worldwide seminars and conferences. He was ranked Band 2 in the World Transfer Pricing 2017 guide.
Abe is the International Tax Director at FenXun Partners. Before joining FenXun, Abe served as the global tax director of Huawei’s Consumer Business Group, overseeing the tax operation of Huawei’s consumer device business, e-commerce, and consumer cloud services worldwide. Prior to that, Abe was the partner in charge of KPMG’s international tax services in the Asia Pacific region and was also the country leader of KPMG China’s international tax practice.
The Westin Paris - Vendôme
3 Rue de Castiglione
Paris 75001 France
Phone: (33)(1) 44771111
A block of rooms is available at the conference venue, The Westin Paris Vendome. A special accommodation rate of €350/night for a single room.
Please contact the hotel directly for reservations or use this link to book online.
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We understand the challenges of the global economy because we have been at the forefront of its evolution. Since 1949, we have advised leading corporations on the issues of today’s integrated world market. We have cultivated the culture, commercial pragmatism and technical and interpersonal skills required to deliver world-class service tailored to the preferences of world-class clients worldwide.
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