14TH ANNUAL Global Transfer Pricing Forum › pdfs › Global TP 2014 › GTPF2014.pdfRandall Fox, Transfer Pricing and APA Specialist, World Bank Group 16.00 Hot topics in global

Global Transfer Pricing ForumSeptember 22-23 2014 | Park Hyatt Hotel, Washington DC

>TO REGISTER, OR FOR MORE INFORMATION:

VISIT www.internationaltaxreview.com/TPForum2014CALL +44 (0) 207 779 8334EMAIL [email protected]

TWITTER #GlobalTP14LINKEDIN GROUP Global Transfer Pricing Forum 2014

14TH ANNUAL

In association with:

TAKE PART IN TWO DAYS OF INTERACTIVE DISCUSSIONS TO ENABLE YOU TO:

> Expand your business contacts by networking with the tax directors of the world’s largest multinationals

> Discover how your peers are dealing with specific transfer pricing matters and benchmark your ownstrategies

> Get the latest updates on the OECD’s BEPS project and find out what key decision makers will do next

> Hear about transfer pricing policy initiatives from various global organisations and what they mean for yourbusiness

> Listen to debates on the most problematic areas of transfer pricing and find out how to tackle them inyour business

14th AnnualGlobal Transfer Pricing Forum

September 22-23 2014 | Park Hyatt Hotel, Washington DC

The 14th annual International Tax Review and TPWeek Global Transfer Pricing Forum will be held in association with Deloitte at the Park HyattHotel in Washington DC on September 22 and 23.

Expert insights will be heard from the US Department of Treasury and the World Bank Group as well as perspectives from some of the world’slargest multinationals including Hewlett-Packard, Nissan and Caterpillar.

This year’s special focus will not only include the G20 and OECD base erosion and profit shifting (BEPS) project but will also look at the impacton the compliance burden of multinational taxpayers from the possible introduction of country-by-country (CbC) reporting. Delegates will alsobenefit from high-level discussions on tax issues in the digital economy, supply chain restructuring and dispute resolution and controversymanagement.

Panel debates will feature speakers from government and in-house tax departments, as well as top transfer pricing advisers where delegatescan expect to hear how best to cope with the compliance burdens and how to combat new audit approaches from government. In addition, thisyear will hold industry-specific break-out panels, to allow for a more targeted approach to transfer pricing planning.

Who should attend:• Corporate tax directors • Revenue officials • Finance directors• Corporate transfer pricing managers • Private practitioners • Transfer pricing economists

Join the Global Transfer Pricing Forum group on LinkedIn for the latest news about the conference.Search: Global Transfer Pricing Forum 2014

Park Hyatt Hotel1201 24th St NW,

Washington, DC 20037,

United States

Special room rates are available for attendingdelegates for September 21-22 2014 from USD319 +tax per night.

To book your room visit:https://resweb.passkey.com/go/ELMG2014

*Please note that all delegates are responsible for theirown accommodation and travel.




Media partners

8.30 Registration and breakfast

9.00 Chair's introduction and opening remarksSophie Ashley, Managing Editor, TPWeekTodd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte

9.10 Keynote addressSam Maruca, Former Director, Office of Transfer Pricing Operations, US Internal Revenue Service

9.30 BEPS: A general updateBEPS is still creating debate about its potential impact on taxpayers.Without final documents and guidance to react to, taxpayers are stilltrying to prepare for possible changes to the way they do business andare looking to review the transactions they have already put in place forpossible risks to audit.• What are the general debates that have arisen during the BEPS

project in the past year?• Recommendations for action based on new material released by the

OECD and its commentators

Tim Tuerff, Partner, Deloitte (moderator)Will Thompson, Director of Transfer Pricing, Brown-FormanDavid Forst, Partner, Fenwick & WestRoy Herzgsell, Head of Transfer Pricing, Colfax Group

10.45 Coffee

11.15 Digital economy issues: Where are we heading?The OECD has published a discussion draft on the "Tax Challenges of theDigital Economy", relating to Action 1 (address the tax challenges of thedigital economy) of the action plan (AP) on base erosion and profitshifting (BEPS). This new OECD discussion draft examines the evolutionover time of information and communication technology (ICT), includingemerging and possible future developments.• Discuss the spread and impact of ICT across the economy • Share examples of new business models• Identify key features of the digital economy

Keith Reams, Partner, Deloitte (moderator)Paul Morton, Head of Group Tax, Reed Elsevier GroupDeborah Van Horn, Senior Director of Tax, IDT – Integrated Device TechnologyMike Bowes, Transfer Pricing Director, Deloitte

12.30 Lunch

13.40 Keynote address: The future of transfer pricingdocumentation

Tracey Rossow, Senior Solution Consultant, Thomson Reuters ONESOURCE

14.00 Industry panel focus: TMT, life sciences,manufacturing

Industry expertise is becoming more and more important in the transferpricing area. This panel will help you understand why and suggest howto address industry dynamics, competitive landscape, innovations, anddisruptions in the pricing models. The industry panel will introduce youto the latest industry-specific pricing models and trends within keyindustry groups: Technology, media and telecommunications, energy, lifesciences, manufacturing and consumer products.

Kristine Riisberg, Principal, Deloitte (moderator)Heather Crowder, Global Head of TP, Conoco PhilipsOgnian Stoichkov, Director, Global Transfer Pricing, PepsiCoAydin Hayri, Principal, Deloitte Kaoru Dahm, Principal & Transfer Pricing Economist, Deloitte

15.15 Coffee

15.40 Keynote addressRandall Fox, Transfer Pricing and APA Specialist, World Bank Group

16.00 Hot topics in global transfer pricingWhile BEPS is holding centre stage in the global transfer pricing debate itis not the only international issue. Various regulation changes in LatinAmerica have had an impact on how taxpayers organise their globalaffairs. The European Commission is also releasing new reports andlaunching investigations into suspected transfer pricing abuse. In Asia,China is relaxing its stance towards OECD guidelines and India releaseda raft of new transfer pricing measures in its 2014 budget, includingacceptance of the interquartile range and use of multiple year data.

Shanto Ghosh, Partner, Deloitte (moderator)David García Morales, International Tax Lawyer, EcopetrolRandall Fox, Transfer Pricing and APA Specialist, World Bank GroupRamón López de Haro, Partner, Deloitte

17.15 Close of day one

17.30 Cocktail reception

All Global Transfer Pricing delegates and speakers arewelcome to join us for drinks, canapés and networking

Sponsors:

Exhibitor:

Day 1 – September 22, 2014




8.30 Registration and breakfast

9.00 Chairman’s opening remarksRalph Cunningham, Managing Editor, International Tax ReviewTodd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte

9.10 Keynote addressRobert Stack, Deputy Assistant Secretary (International Tax Affairs), US Department of Treasury

9.30 BEPS: A detailed discussion of recently releasedfinal guidance on TP documentation and country-by-country reporting

Entrenched in the BEPS debate is the concept of country-by-country(CBCR) reporting. CBCR has evolved from a fringe concept to a globalreality in a relatively short space of time. It could mean that individualjurisdictions have a better idea of a company's global tax payments butit could also implicate a significant compliance burden for taxpayers ifnot handled correctly.• What will it mean for multinational companies and how will it affecttheir transfer pricing compliance?• Discuss the controversial aspects of CBCR whilst giving tips totaxpayers about the best ways to manage its impact on their company

Mark Nehoray, Managing Partner, Deloitte (moderator)Sameer Chaudhary, Americas Transfer Pricing Manager, Hewlett PackardInga Kondrataite, Head of Transfer Pricing, AMIE (Africa, Middle East, India and Europe), NissanAndrew Kim, Partner, Fenwick & WestDarcy Alamuddin, Partner, Deloitte

10.45 Coffee

11.15 The profit split methodWhile the US transfer pricing regulations refer to the "profit split method",there are two methods that fall under this heading.This panel will focus on:• Value creation• Intangible issues• Different models• Location specific advantages

Rob Plunkett, Principal, Global & US Financial Service TP Leader, Deloitte (moderator)Andrea Bonzano, Head of Tax, FiatFrank Schoeneborn, Head of Global Operational Transfer Pricing Management, Merck GroupBoris Nemirov, Tax Principal/Partner, Transfer Pricing, Deloitte

12.30 Lunch

13.40 Keynote addressA step forward to mitigate Transfer Pricing risks – a global ISOcertification on TPDr. Knut Olsen, Global Tax Practitioner & Adjunct Tax Professor,Dr. K. Olsen Global Tax Consultant

14.00 Supply chain restructuring and intangible planningin the current environment

Considering the uncertainty surrounding intangible assets, supply chainrestructuring has become an even more risky business for taxpayers inrecent years.• Focus on business transformations to create entrepreneurial

structures within a group of companies• Discuss best practices and determine the different types of

intellectual property a company could be dealing with• How these different types of IP will affect restructuring

John Wells, Principal, Deloitte (moderator)Dr Napoleão Dagnese, Head of International Tax, OC OerlikonDon Maher, Director of Tax Planning, The Dow Chemical CompanyMichael Gilson, Partner, DeloitteWill Thompson, Director of Transfer Pricing, Brown-Forman

15.15 Coffee

15.45 Dispute resolution and controversy management:Emerging issues

Each year, more and more rulings are being made in various high courtsand tax courts around the world. All of these rulings, if not binding in lawoutside of the particular country, have lessons for taxpayers; slowly helpingto build a clearer picture about the art of transfer pricing.• Hear from notable transfer pricing case studies• Cover new tactics for audit defence, taking a long-term view on the

risks of transfer pricing controversy• In-house counsel will provide their first-hand experiences

Rob O'Connor, Partner, DeloitteKatherine Amos, VP, TP Strategy, EATONKeith Richey, International Tax Counsel, Xylem IncCindy Hustad, Director, Tax Controversy Services, DeloitteJames R. Gadwood, Sullivan & Cromwell

17.00 Close of day two

Day 2 – September 23, 2014




Americas Tax AwardsSeptember 18, 2014

Grand Hyatt, New York

For further information and table bookings, contact MeganPoundall at [email protected].

ADMINISTRATIVE INFORMATIONCANCELLATION POLICY: If you cannot attend you must cancel your registration inwriting by 25 August 2014 to receive a refund less a 10% administration charge.Cancellations received after 25 August, or no shows, are liable for the full conferencefee (where applicable). You may send a substitute to attend in your place at no extracharge, however we must know by 15 September 2014 via email. We cannot acceptverbal cancellations. If you make your booking online, by email or via the telephone,you are automatically adhering to our terms and conditions.

REGISTRATION:The registration fee includes participation in the forum on both days,documentation materials, breakfast, coffee breaks, lunches and a cocktail reception at theend of day one. All delegates are responsible for their own accommodation and travel.

PAYMENT: All registration fees must be received in full prior to the event date.

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14th Annual Global Transfer Pricing ForumSeptember 22-23, 2014 | Park Hyatt Hotel, Washington D.C.

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14TH ANNUAL Global Transfer Pricing Forum › pdfs › Global TP 2014 › GTPF2014.pdfRandall Fox, Transfer Pricing and APA Specialist, World Bank Group 16.00 Hot topics in global