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Re-evaluating Transfer Pricing Risk in Today's BEPS Environment

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DESCRIPTION

For the last two years, tax practitioners have followed the developments of the OECD’s Base Erosion and Profit Shifting (BEPS) project.  Topics have ranged from whether the OECD should be addressing the issue, to what the OECD intended, to what the BEPS project will actually require from taxpayers in terms of compliance once its approaches have be adopted by the tax authorities of various countries. To date, little attention has been focused on the likely impact of the BEPS proposals on taxpayer exposure to transfer pricing adjustments and double tax and actions taxpayers should take to mitigate that risk.

This presentation will identify the additional risk imposed by the country-by-country reporting requirements and how that additional exposure should be reflected in financial statement reserves. Further, this presentation will suggest potential ways to evaluate and mitigate the additional risk.

Educational Objectives:
• Understand the BEPS reporting obligations
• Appreciate the additional compliance efforts required
• Foresee the additional transfer pricing exposure
• Formulate an approach to mitigate the additional exposure

Who would benefit most from attending this program?
CFO, VP Tax, International Tax Directors, Transfer Pricing Directors.

SPEAKERS

STEVEN C. WRAPPE, NATIONAL LEADER FOR TRANSFER PRICING DISPUTE RESOLUTION AT KPMG LLP

Steve is a globally-recognized transfer pricing professional with nearly 25 years of transfer pricing experience, both for the government and in private practice.  He is an adjunct faculty member at New York University School of Law, Georgetown University Law Center, and the University of Florida School of Law.  He recently published the fourth edition of his leading U.S. transfer pricing treatise: Transfer Pricing: Rules, Compliance and Controversy (Wolters Kluwer/CCH, 2013).  Steve’s transfer pricing controversy experience includes examination, appeals, alternative dispute resolutions, advance pricing agreement (APAs), mutual agreement procedures (MAP), and Customs agreements.  He is one of the most experienced APA or MAP negotiators at any firm, with a combined experience of more than 150 cases.


KARA BOATMAN, PHD, PRINCIPAL AT KPMG US

Dr. Boatman (Kara) has 20 years of experience in transfer pricing and valuation.  Kara has served clients in a variety of industries, including technology, pharmaceutical, biotechnology, manufacturing, transportation, and consumer products. As leader of the Bay Area transfer pricing practice, Kara specializes in intangible property valuation and migration, transfer pricing planning, and global compliance for technology and life sciences clients.  Her recent projects include designing and implementing an IP migration strategy for a pharmaceuticals company; directing a global documentation study for a software company; presenting a software company’s response to the IRS in a transfer pricing dispute; and directing a global documentation study for a medical device company.