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Transfer Pricing Intro: Coming Audits and Coming Changes

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DESCRIPTION

The term "transfer pricing" relates to all international transactions performed between related parties, the most common being distributorship, R&D, marketing, manufacturing, loans, management fees, and IP licensing. All such intercompany transactions must be regulated in accordance with applicable laws (in the US and elsewhere) and must comply with the "arm's length" principle, which requires the transaction to be conducted as if performed between unrelated parties.

Transfer pricing audits by worldwide tax authorities are on the rise, with senate looking into transfer pricing schemes and cases brought before the court constantly, both in the US (for example the Amazon case), in Canada (for example the GSK case), and in other counties (such as P&G in Argentina, Verizon in India, Amazon in the EU, and many more).

The OECD has enacted new recommendations on transfer pricing, referred to as the Action Plan on Base Erosion and Profit Shifting ("BEPS"). The new BEPS regulations are a true game changer, requiring multinationals to disclose its financial and other sensitive information in each jurisdiction in which it is active, based on a new set of forms developed by the OECD.

Educational Objectives:
• The realms covered by transfer pricing, in the US and ROW;
• Common practices to price intercompany transaction;
• Focus shifting in transfer pricing tax audits worldwide;
• Recent case law from the US, Canada and other important countries;
• The new OCED BEPS regulations and Country-by-Country reports to be soon filed by all multinationals;
• BEPS readiness and the new instructions adopted by Spain, Japan, the UK, and Australia.

Who would benefit most from attending this program?
Transfer pricing professionals, corporate tax counsel, tax attorneys at law firms, tax litigation attorneys.

Herzog Fox & Neeman (HFN) is Israel’s largest and most diverse law firm, representing international clients in Israel and abroad. HFN's transfer pricing practice is honored around the globe, representing hundreds of international clients in transfer pricing matters throughout the world, with an unmatched 100% success rate of its transfer pricing studies in tax audits worldwide.

SPEAKERS

YARIV BEN-DOV, HERZOG FOX & NEEMAN

Yariv is an expert in drafting and defending transfer pricing studies and intercompany agreements, with over 12 years of experience. Yariv counsels both multinational conglomerates and small start-ups on their transfer pricing matters, including multinationals which have no activity in Israel.

Prior to joining HFN, Yariv was a co-founder of Bar-Zvi & Ben-Dov, a boutique law firm specializing in transfer pricing and high-tech, and prior to that Yariv served as the Transfer Pricing Manager and as the Head of the Transfer Pricing Unit in Teva Pharmaceuticals.

Yariv has published articles in the subject of transfer pricing and has been asked to keynote as an expert in transfer pricing at several conventions in Israel, Europe and the US.

Yariv is a member of Transfer Pricing Associates, the world's largest network of independent transfer pricing experts, a member of the Israeli Bar Tax Committee, and of the Board of the Israeli-LATAM Chamber of Commerce. Yariv is also a Board member of the Arthur Rubinstein Music Society and the head of the Society's NYC branch. Yariv counsels (pro bono) to the Israeli Navy Association.


EYAL BAR-ZVI, HERZOG FOX & NEEMAN

Eyal Bar-Zvi specializes in the fields of transfer pricing, start-ups, high-tech and corporate law. He is experienced in advising MNEs on their local and international intercompany transfer pricing and transactions, as well as in advising start-ups from their incorporation stage through the M&A.

Eyal is an adjunct professor in the Haifa University Faculty of Law, where he teaches a course in Securities Law and a course in High-Tech investments. Prior to joining HFN, Eyal was a co-founder of Bar-Zvi & Ben-Dov, a boutique law firm specializing in transfer pricing and high-tech, and prior to that he worked for five years in the offices of Prof. Gross, Kleinhendler, Hodak, Halevy, Greenberg & Co., where he worked directly with the firm's founder, Prof. Joseph Gross.

Eyal is a member of Transfer Pricing Associates, the world's largest network of independent transfer pricing experts, a member of the Israeli Bar High-Tech Committee, and of the Israeli Advanced Technologies Industries Association. Eyal is also a member of the Haifa University Faculty of Law Alumni Board, and of the German-Israel Legal Association. Eyal counsels (pro bono) to the Tel-Aviv University's Entrepreneurial Center.