TP Minds Hong Kong Nov 2015

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Mark Konza ATO

Terence Yuen BP

Vatika BhatnagarAIRTEL

Sam Sim IBM

Duo Wu SIEMENS

Jacquie Chan LEAR CORPORATION

Ilka Ritter UNITED NATIONS

3 - 4 November 2015, Intercontinental Grand Stanford Hotel, Hong Kong Technical Workshops - 2 November 2015

Inspiration50+ Speakers

20+ Presentations & Panels

4 Workshops

Networking150+ Attendees

70% Corporate Attendees

20+ Industries Represented

To register or for the latest information, please visit: www.ibc-events.com/TPAsia Tel: +44 (0) 20 7017 7790 Email: [email protected]

The World’s Leading Independent Transfer Pricing Forum Now FREE for Senior In-House Professionals in APAC

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2 November: Pre-conference Workshops

3 - 4 November: Main Summit Days


Dear colleague,

The international tax landscape is being redefined by BEPS and other OECD-led projects, which are likely to shape the way you think, design and apply your TP policies into the future. It is therefore critical that you keep abreast of these changes and fully understand the practical impact these will have for your present and future tax arrangements.

We have therefore lined-up a number of seasoned heads of tax and transfer pricing, as well as key policy makers and tax authorities, to provide not only critical insights into what the impact of the latest TP developments may be on MNEs, but also share best practice advice on how some of the more challenging TP issues are being addressed within their organizations.

You’ll once again have an opportunity to hear from speakers from some of the world’s largest corporations and exciting brands such as General Electric, HSBC, Intel, IBM, Alcatel-Lucent, BP and Nissan Motors to name just a few. Whether as part of an industry panel session or delivering a solo presentation or case study, we’re sure you’ll find listening to their views an invaluable experience.

Past delegates will notice the agenda has its fair share of new faces so you can benefit from a diverse and exciting range of views from across different industries and jurisdictions, but we made sure to continue to allow maximum exposure to those speakers who have consistently delivered high value contributions to TP Minds.

We have been careful to make sure the summit remains industry-led, which is why most of our speaker faculty is comprised of in-house TP directors. Professional advisors also continue to play a key role in adding to the level of technical sophistication to the agenda.

I would also like to draw your attention to our four pre-conference technical workshops – a popular perennial in the TP Minds series, which consistently attract great reviews from participants. This will be a great way to gain in-depth understanding of the changes afoot with regards to Documentation and Country-by-Country Reporting, Hard to Value Intangibles & Cost Contribution Arrangements, TP Risk Management after BEPS, and Supply Chain.

Last but not least, if you’re a senior in-house tax or transfer pricing professional with a large multinational company you will be able to apply to attend TP Minds Asia entirely free of charge! Simply email me directly on [email protected] to secure your place. What better way to be able to benchmark your organization’s response to the fast-evolving transfer pricing agenda then to attend the leading TP forum in Asia as our VIP guest?

I’m sure you’ll find attending TP Minds Asia 2015 one of the most rewarding and efficient ways to sharpen your TP knowledge and I look forward to personally welcoming you to Hong Kong in November.

Best regards,

Michele Costa, TP Minds Asia

Page 3 Programme at a Glance

Page 4 Editor’s Choice

Page 5 New Presentations & Case Studies

Page 6 - 9 Meet 50+ TP Leaders

Page 10 - 13 Summit Day One

Page 13 - 16 Summit Day Two

Page 17 - 18 Pre-Conference Technical Workshops

Page 19 Supporters of TP Minds Asia 2015

Page 20 Booking Form

event schedule

Contents

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Tuesday 3 November

Main Summit Day 1

TP MINDS ASIA 2015 PROGRAMME AT A GLANCE

A choice of 4 highly interactive and technically sophisticated workshop sessions designed to allow you to dive deeper into critical aspects of Transfer Pricing. Don’t miss the half-day briefings on Global Documentation & Country by Country Reporting as well as Hard to Value Intangibles & Cost Contribution Arrangements.

Key SpeakersAnis Chakravarty, DELOITTE (India)Alan Shapiro, DELOITTE (Japan)Jun Sawada, DELOITTE (Japan)Carlo Navarro, DELOITTE (Indonesia)Fabrizio Lolliri, HOGAN LOVELLS

Monday 2 November

Technical Workshops

Big Themes• Documentation & CbCR• Hard to Value Intangibles &

CCAs• Assessing TP Risk after BEPS• Supply Chain Management

Day 2 will focus heavily on intangibles, comparability and economic aspects of TP such as valuation issues, among a number of other critical issues. You’ll benefit from a full round-up of TP issues across South East Asia, as well as the broader tax landscape beyond transfer pricing with a particular emphasis on Customs. Last but not least you’ll benefit from authoritative advice on Intragroup Financing provided by a number of experts in the field.

Wednesday 4 November

Main Summit Day 2

Big Themes• BEPS & Policy Developments• Country by Country Reporting• Managing TP Audits• The Future of APAs• Low Value-Adding Services

Key SpeakersMark Konza, ATO Ilka Ritter, UNITED NATIONSJean-Louis Barsac, ALCATEL LUCENTSam Sim, IBMScott Campbell, FMC TECHNOLOGIESTobey Hill, CITIGROUP

Explore the continued impact of BEPS and CbCR on TP risk management and policy implementation strategies for MNEs. Understand how best to navigate the present audit landscape, the evolving role of APAs and listen to practical industry case studies, presented by seasoned heads of transfer pricing and group tax directors at the coal face of the latest global TP developments.

Big Themes• Intangibles and Comparability • Valuation Issues in Transfer

Pricing• TP Controversy & ADR• Intragroup Financing • The wider tax landscape beyond

TP

Key SpeakersMorrie Cheng, SUN LIFE FINANCIALRavi Lakdawala, BAYERDuo Wu, SIEMENSChang Lee, NOMURA INTERNATIONALDinesh Agrawal, HSBCChristopher Newman, DUFF & PHELPS


@TPsummit www.youtube.com/ITPSummitTV LinkedIn Group: TP Minds

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EDITOR’S CHOICE


ATO Keynote SpeechMain Conference Day 1, Tuesday 3 November An unmissable presentation by the ATO’s Deputy Commissioner Mr Mark Konza, giving the Australia perspective on Multilateral and Unilateral Developments in relation to BEPS. This will also be a unique opportunity to listen directly from the ATO on recent developments concerning APAs in Australia, and much more besides.

Global Tax TransparencyMain Conference Day 1, Tuesday 3 November As transparency continues to dominate the global transfer pricing agenda we assembled a panel of seasoned professionals to reflect and share their views on the key issues coming out of this continuing debate. Sam Sim, Transfer Pricing GEO Leader at IBM (pictured) will be joined by other leading minds in the field to discuss this burning issue.

Hard to Value Intangibles & Comparability Main Conference Day 2, Wednesday 4 November Industry speakers including Vatika Bhatnagar, Transfer Pricing Manager at Airtel (pictured) will come together to debate intangibles and comparability issues, namely hard to value intangibles, applying the profit split method in practice, the challenges of working with imperfect comparables and much more besides. Listen to representatives from Siemens, Bayer, BvD and Relx Group.

Future Outlook for APAS Post-BEPS Main Conference Day 1, Tuesday 3 NovemberWill the final guidance on BEPS see an increase in demand for APAs? Will unilateral actions by countries in Asia make it more challenging for taxpayers to comply? Nomura’s Head of Transfer Pricing for Asia, Chang Lee (pictured) and several other in-house professionals will share their views on these and many other pressing questions surrounding the future of APAs.

International TP Policy Developments Main Conference Day 1, Tuesday 3 NovemberThis year’s TP policy panel session will feature key international policy making bodies including the United Nations, represented by Ilka Ritter. You’ll also hear from leading tax authority representatives including Mr Brian Chiu (pictured) of the Hong Kong Inland Revenue Department, Mark Konza, of the ATO, Kriti Velji of the New Zealand Inland Revenue Department and others prominent speakers.

Transfer Pricing ControversyMain Conference Day 2, Wednesday 4 NovemberTerence Yuen, Regional Head of Tax, Asia Pacific at BP (pictured) joins an authoritative speaker line-up featuring Amit Gupta of Dell, Scott Campbell of FMC Technologies (US) and Arun Sethi of Nepture Orient Lines (NOL) to discuss the latest global TP controversy developments.

Low Value-Adding Intragroup ServicesMain Conference Day 2, Wednesday 4 November Moderated by Fabrizio Lolliri of Hogan Lovells, this industrypanel will focus on BEPS discussion draft on Action 10 – Lowvalue-adding services. Industry panellists featured include Frank Shao, Head of Tax at Merck China (pictured), Dinesh Agrawal of HSBC, Adnan Begic of Michelin Asia Pacific and others.

Latest Developments at UN LevelMain Conference Day 1, Tuesday 3 NovemberIlka Ritter of the United Nations’ International Tax Cooperation Section (pictured) delivers an insightful address to our audience focusing on the latest TP developments at UN level including an update future of UN “norm development” in light of the UN Addis Ababa conference.

With over 40+ speakers packed into 3 days of essential content, the Conference Director for TP Minds Asia, has selected some of the sessions you cannot afford to miss.

5To register or for the latest information, please visit: www.ibc-events.com/TPAsia Tel: +44 (0) 20 7017 7790 Email: [email protected]

SPOTLIGHT ON BEPS, DoCUMENTATION & CBCR

The Pre-Conference Workshop Expertly led by Anis Chakravarty (pictured) and Alan Shapiro, both partners at Deloitte, the half-day pre-conference workshop on “Global Documentation & Country-by-Country Reporting” is designed to be an unrivalled resource for the consolidation of best practices to comply with the new requirements and the actions companies should consider now to mitigate the risks associated with the increased transparency of their transfer pricing policies and three tiered approach to documentation. You will benefit from more than 3 hours of training including the opportunity to put questions to the workshop leaders.

The Thought Leadership PresentationJean-Louis Barsac, Group Transfer Pricing and APAC Tax Director at Alcatel Lucent will analyse the new Documentation/CBCR landscape in the context of BEPS’ pledge for Transparency. This insightful thought leadership presentation will analyse what the new corporate transparency culture really means for business in terms of resources and mindset. As Jean-Louis warns, multinationals are under perpetual audit! Make sure you’re prepared for what’s to come from 2016 onwards.

MNCs TP Risk Management in China’s Evolving TP LandscapeDuo Wu, Asia Tax Director at Siemens will deliver an insightful presentation, exclusively put together for TP Minds Asia, analysing China’s evolving TP landscape and the risk minimisation tools multinationals should be considering. The presentation will provide an overview of the Chinese tax authority’s position in relation to multinationals’ tax arrangement and reflect on whether post-remediation should be preferable to prior risk control in the present environment, among many other important considerations. Not to be missed.

The Industry Case StudyScott Campbell, Global Transfer Pricing Manager at US multinational FMC Technologies, based in Houston, will help demonstrate how industry should be preparing to “Reconsider the Post Apocalyptic World of BEPS Documentation Requirements & Disclosures” and prepare for the new three-tiered approach. Scott’s case study will centre around some key data concerns, namely surrounding: timelines and possible penalties, confidential information security, costs for MNEs and much more besides.

The Industry Panel SessionEntitled “Managing Transfer Pricing Risk after BEPS & CbCR” this industry panel session will assemble leading Asia-Pacific tax and transfer pricing minds including Tobey Hill of Citigroup (pictured), Jessie Kavanaugh of Intel Semiconductor, Jean-Louis Barsac of Alcatel Lucent, and Adnan Begic, Asia-Pacific Transfer Pricing Director for Michelin. The panel will share tips on practical risk minimisation strategies and explore potential risks to the Board, audit committee and auditors in a must-attend plenary session of essential attendance for tax directors.

Transfer Pricing and CustomsRishabh Sawansukha, VP Taxation at Indian e-commerce giant Snapdeal briefs delegates on the always complex area of Transfer Pricing and Customs focusing on the conflict of interest and valuation of intangibles in joint development plans. Rishabh will take a close look at Custom disputes and interplay with local indirect taxes, related party transactions, valuation disputes, post clearance custom audits and much more besides.

TP Minds Asia 2015 will be casting a spotlight on the most pressing challenges posed by BEPS with regards to Documentation and Country-by-Country Reporting with comprehensive coverage in the forms of individual presentations, case studies, panel debates and workshops including the following sessions:

OTHER OUTSTANDING STANDALONE PRESENTAtIONs BY INDUSTRY EXPERTS INCLUDE

6 To register or for the latest information, please visit: www.ibc-events.com/TPAsia Tel: +44 (0) 20 7017 7790 Email: [email protected]

MEET 50+ TP LEADERS & ADVISERS INCLUDING...Mark Konza Deputy Commissioner ATOAs Deputy Commissioner, International, Mark is responsible for the strategic leadership of international taxation

issues and risks. These responsibilities include driving collaborative approaches to ensure jurisdictions get their fair share of tax, developing a range of mitigation strategies within the ATO’s International focus and managing domestic and international responsibilities to address corporate tax base erosion and profit shifting (BEPS). Mark has qualifications in both accounting and law. His 30 plus years in the Australian Taxation Office has spanned across many different tax technical and management roles. At various times he has been the Deputy Commissioner responsible for the administration of taxation of individuals, small businesses, and large and multinational enterprises. He represents the Australian Taxation Office at the OECD’s Task Force on the Digital Economy and is an IMF Fiscal Affairs Expert.

Ilka Ritter Associate Expert, International Tax Cooperation Section UNITED NATIONSMiss Ilka Ritter is currently Associate Expert in the International Tax

Cooperation Section of the UN’s Financing for Development Office in New York, working in particular on transfer pricing issues and the taxation of the extractive industries. In her previous functions, she advised parliamentarians and governments on taxation and governance issues while working for German Technical Cooperation (GIZ), Friedrich Ebert Stiftung and the European Commission. Previous to obtaining a Master in Public Policy, Ilka Ritter studied for a B.Sc. in International Business Studies and a B.A. in European Studies both at University Maastricht.

Terence Yuen Regional Head of Tax, Asia Pacific andCountry PresidentBP Terry Yuen joined BP in Singapore as its Regional Head of Tax for Asia Pacific on

May 2, 2013. Terry has over 25 years of international taxation experience, holding many senior positions. Effective 1 January 2014, Terry has also become the Country President for BP Singapore, overseeing the businesses and seven hundred staff located in Singapore. As the Regional Head of Tax for Asia Pacific, Terry has accountability for all tax and customs related matters in the region, including planning, advisory, compliance, reporting and advocacy. He manages a team of sixty five tax professionals across the region.

Jacques Van Rhyn International Tax and Transfer Pricing Partner DELOITTEJacques Van Rhyn is an international tax and transfer pricing partner, and

national leader of the Deloitte Transfer Pricing team in Australia. He has also founded Deloitte’s Australia-Africa Services Group, based on his experience in dealing with international tax and transfer pricing issues faced by multinational companies investing into Africa or with African operations. Jacques has been practising for over 20 years and has extensive experience advising multinational companies on various cross-border tax and transfer pricing issues, including assisting clients to defend their transfer pricing arrangements in risk review and audit situations. Jacques has also advised companies in relation to structuring their international operations to achieve sustainable and defensible tax risk management policies aligned with commercial operations. Jacques has managed several multi-jurisdictional international tax and transfer pricing projects for multinational groups, from both a compliance and planning perspective. Jacques is able to provide a seamless service offering across multiple countries given his strong global networks, knowledge of the OECD Guidelines, double tax treaties and in-country transfer pricing rules, and awareness of revenue authorities’ enforcement of these rules in various jurisdictions.

Kriti Velji National Transfer Pricing Advisor INLAND REVENUE DEPARTMENT (New Zealand)Kriti has been employed with the Inland Revenue Department for the

last nineteen years in various positions within the Department including: Investigator, Team Leader (Investigations), Manager (Investigations) and she currently holds a position of a Principal Advisor Transfer Pricing. In her current role, Kriti is responsible for the negotiation of Advanced Pricing Agreements, providing technical transfer pricing analysis, providing support and training for Investigation staff and the resolution of complex transfer pricing disputes. Kriti is a Chartered Accountant and a member of the New Zealand Institute of Chartered Accountants.

Sam Sim Transfer Pricing GEO Leader Asia-Pac & Japan IBMMr Sam T Y Sim is Transfer Pricing GEO Leader Asia-Pac & Japan for IBM.

Before joining IBM he was Head of Transfer Pricing (East) for Standard Chartered Bank in Singapore, a U.K. global banking group with networks in over 70 countries with a focus on Asia, Africa and the Middle East. He led a team of professionals in Singapore and India covering tax transfer pricing globally for the institutional and commercial banking businesses of Standard Chartered across Corporate Finance, Global Markets (including FICC and Equities), Capital Markets & Syndications, Principal Finance and Transaction Banking. Prior to joining Standard Chartered Bank, Mr Sim was previously a tax attorney in New York and an Assistant Director at the Monetary Authority of Singapore. He has a B.A. and M.A. (Economics) from Cambridge University, an L.LM (Taxation) from New York University and is a qualified attorney of both the New York and Singapore Bars.

Scott Campbell Global Transfer Pricing Manager FMC TECHNOLOGIESA graduate from the University of Arkansas School of Law in 1997, Scott is presently Global Transfer

Pricing Manager for FMC Technologies Inc based in Houston, Texas. Scott previously worked for Celanese Corporation, a Fortune 500 MNE chemical company, which he joined in 2005. Scott led the global transfer pricing practice at Celanese (USD $5billion annually in intercompany tangible product transactions) for intercompany transactions relating to tangible products, shared services, IP, royalties, intercompany loans, guarantees and cash pooling.

Ravi Lakdawala Head of Transfer Pricing and International Tax BAYERRavi Lakdawala is Head of Transfer Pricing & International Tax at Bayer

India. Ravi is responsible for a number of TP functions including Transfer Pricing compliance, and advisory, group audits, Transfer pricing litigation at higher appellate authorities and other responsibilities. Prior to joining Bayer, he worked for 3 years with the transfer pricing services at PwC, one of the “Big Four” firms and Shell. He has undertaken numerous planning and documentation projects to determine the arm’s-length compensation for tangible property, intangible property and services.

Masako Hikota Manager of Taxes; Japan IBMMasako Hikota is Manager of Taxes for IBM Japan. Prior to joining IBM, Masako Hikota was a member of the

Global Tax team at Rakuten, Inc. in Tokyo, Japan. She has considerable experience in developing solutions to a wide range of complex international tax issues and in the practical planning and implementation of new businesses in Asia, Europe, Americas and rest of the world. She specializes in international/global tax planning, corporate reorganizations and reconstructions, M&A and tax risk management. Masako has extensive

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MEET 50+ TP LEADERS & ADVISERS INCLUDING...experience in advising Japanese MNCs with respect to cross-border/cross-functional structuring and restructuring.

Jackie Chan APAC, Tax Director LEAR CORPORATIONJackie has more than 15 years of experience in the tax industry of which, the first 10 years were spent

in professional firms such as Ernst & Young and KPMG, before joining Lear Corporation (Shanghai) Limited (“Lear Shanghai”) in 2008 working as a Tax Director. His prime responsibility as a Tax Director of Lear Shanghai is to oversee the tax matters in the Asia Pacific region covering Korea, Japan, China, Philippines, Indonesia, Malaysia, Vietnam, Australia, India, Singapore, Thailand and Mauritius.

Morrie Cheng Head of Tax - Asia SUN LIFE FINANCIALMorrie Cheng is Head of Tax, Asia of Sun Life Financial. He has responsibility for Sun Life’s tax function in Asia. Mr.

Cheng joined Sun Life in 2008. Mr Cheng has a wide range of international tax and insurance tax experience including Associate Asia Tax Director at Swiss Re and Regional Head of Tax at Henkel. Mr Cheng holds a Bachelor of Arts in Accountancy from City University of Hong Kong and is a qualified chartered accountant.

Duo Wu Asia Tax Director SIEMENSWu Duo has been engaged in the accounting, internal audit and tax fields for nineteen years. She joined Siemens

in 2004. Prior to that, she worked for Hong Kong listed state-owned company as the finance manager and the internal auditor. With great interests in the transfer pricing, she is building up the professional skills in the TP area with open and serious manner. Being the senior tax manager of Siemens TP, her TP experience covers a wide range of issues, across multiple business units and different locations in Main Land China, Hong Kong and Tai Wan, with particular focus on TP audit defense and effective tax control. Through various

TP audit defense cases, she has accumulated rich experiences to negotiate with different level of tax authorities in China. She is a CPA of China.

Jean-Louis Barsac Group Transfer Pricing and APAC Tax Director ALCATEL-LUCENTJean-Louis Barsac heads up the APAC group transfer pricing and tax function

at Alcatel-Lucent, a Fortune 500 telecom equipment and solutions supplier, formed in 2006 by the merger of Alcatel and Lucent. Jean-Louis is overseeing 20 countries including major Asian markets such as China, India, Japan and Australia, with a total revenue over 3 Billion Euros and over 70 legal entities. Jean-Louis is involved in operational and corporate tax management including commercial tax issues, M&A and internal restructuring, cash management and other projects involving tax consequences. Before joining Alcatel-Lucent, Jean-Louis was the Africa and Middle East regional tax leader for Stolt Offshore (now Subsea7), an oil & gas engineering and construction company.

Patrick Cheung Transfer Pricing Partner DELOITTEPatrick is a Transfer Pricing Partner and the Leader of the South China Transfer Pricing practice for Deloitte China.

Prior to joining Deloitte, Patrick was a senior transfer pricing partner of another Big Four accounting firm in Hong Kong. Patrick began his Big Four international tax and transfer pricing consulting career 15 years ago in Canada. Prior to that, he has also worked for the Canada Revenue Agency. Patrick is recognized by LMG’s Expert Guides as a Leading Transfer Pricing Adviser in Hong Kong. Patrick is part of the Joint Liaison Committee for Taxation Transfer Pricing Committee that advises the Hong Kong Inland Revenue Department on Transfer Pricing policy matters. He is also a frequent speaker at PRC State Administration of Taxation Transfer Pricing.

Chang Lee Head of Transfer Pricing (Asia, excl. Japan) NOMURAChang is Nomura’s head of transfer pricing for Asia ex-Japan. He is

responsible for all transfer pricing matters across 13 jurisdictions in which Nomura operates in the region. Chang has over 9 years of experience in tax and transfer pricing, having worked previously for the Australian Taxation Office as a litigator and Deloitte Australia as a transfer pricing specialist. Chang is an Australian solicitor and holds a Master of Laws in taxation.

Dinesh Agrawal Senior Transfer Pricing Manager- MENA HSBCDinesh is Regional Senior Transfer Pricing Manager for Middle East & North Africa at HSBC and responsible

for all TP matters in MENA. Prior to joining HSBC, Dinesh worked with Hewlett-Packard as Global Lead for intra-group financing, and instrumental in drafting HP’s inter-company financing transfer pricing policy. He has been directly accountable for all audit-defense documentation pertaining to intra-group financing activities. Besides, he has also worked extensively in intra-group cost allocations and recharges and global contracts allocation.

Ketan Madia Vice President - Tax GENERAL ELECTRICKetan Madia is Vice President - Tax in the GE India Corporate Tax team and brings with him over 18 years of varied

tax, finance and operations experience. Ketan started his career with Arthur Andersen in 1994, advising MNCs across industry segments on tax treaties, local taxes, foreign direct investment and exchange control regulations. He joined the GE Tax Team in 1999 and in his current role focuses on tax issues related to GE’s industrial and infrastructure businesses, with specific oversight for big-ticket M&A transactions and high stake litigations.

Vatika Bhatnagar Transfer Pricing Manager AIRTELVatika Bhatnagar has an experience of more than 7 years in transfer pricing, both in Consulting as well as Industry.

She is presently working as a Transfer Pricing expert for Bharti Airtel’s foreign subsidiaries, which includes 17 subsidiaries in Africa and 10 in rest of the world. She is responsible for the Transfer Pricing policy and control of transfer pricing performance for all group companies. Apart from this, she is responsible for litigations in various countries involving transfer pricing matters.Prior to joining Airtel, she was part of PwC Transfer Pricing team, where her profile varied from transfer pricing litigation, advisory and compliance. Apart from this, she was responsible for evaluating and advising clients on intercompany transfers of tangible goods, intangible property, services and loans.

Frank Shao Head of Tax MERCKFrank Shao is the head of tax for Merck China based in Shanghai. He is responsible for all tax matters of Merck

entities (both chemical and pharmaceutical business) in Mainland China and Hong Kong. Frank engages building Merck China’s transfer pricing framework for new investment and business arrangement in this area under Merck’s transfer pricing guideline as well as the local transfer pricing regulation. Prior to this role, Frank has spent 8 years in multinational companies and CPA firms as tax advisor including 4 years specialized in transfer pricing. His TP experience covers documentation, advisory, audit defense, and APAs, mainly for industrial companies and/or corporate banks in China mainland and Japan.

Luis Carrillo Transfer Pricing Director BUREAU VAN DIJKLuis Carrillo is a transfer pricing economist with over 8 years of consulting experience, including Big Four

firms, with focus on intangible property valuations and global transfer pricing compliance. Mr. Carrillo is currently responsiblefor developing global software solutions



for transfer pricing for corporate tax departments and practitioners. Mr. Carrillo holds a BA in Economics from the University of California, Santa Cruz.

Jesse Kavanagh Tax Director, Greater Asia Region INTELJesse Kavanagh is Tax Director (Greater Asia Region) for Intel Corporation. Before joining Intel, Jesse was Nomura’s

Head of Tax for Asia-ex-Japan, and was previously Asia Pacific tax head for Lehman Brothers and Partner at a Big-4 firm. He’s worked in Hong Kong and Sydney, specializing in international tax, financial services and mergers and acquisitions. Jesse is the Chairperson of the Capital Markets Tax Committee and has written a number of articles on financial services taxation and spoken at numerous seminars on international tax.

Patrick Connolly Senior Tax Director, Asia JABIL CIRCUITPatrick is a senior Asia Tax Director with Jabil Circuit in Singapore. Prior to joining Jabil Circuit, Patrick was a

senior Tax Advisor to New Zealand’s sovereign wealth fund, the New Zealand Superannuation Fund. Prior to this role, Patrick spent 10 years in two senior regional tax management roles for the world’s largest global milk processor and dairy exporter, the Fonterra Co-operative Group Ltd. The roles were responsible for all tax management for the commodity ingredients and consumer brands divisions in Asia (including customs responsibilities) and then the Europe/Middle East/Africa regions.

Danny Beeton Managing Director, Transfer Pricing DUFF & PHELPSDanny advises on the pricing of all types of transactions and the valuation of intangible assets, with a particular focus

on international tax planning and transfer pricing dispute resolution. Danny is a member of several related industry committees and the editor of a leading transfer pricing journal. He received his PhD in economics from Queen Mary College, London.

Amit Bhalla VP, Tax & Customs APACSCHNEIDER ELECTRICAmit Bhalla is the Vice President Tax & Customs APAC for Schneider Electric based in Singapore. In his role, he is

responsible for the tax & customs affairs for the region, which includes Greater China, Japan, India, Australia, New Zealand and South East Asia region. Amit began his tax career in India with the accounting firm Arthur Andersen in 1994 and was in tax consulting for more than 8 years. Thereafter, he moved into industry specialising in the technology sector. He worked for Huawei Technologies, Cisco Systems and more recently Nortel Networks. During his career, he has worked and lived in India, China, UK and Singapore.

Amit Gupta Tax Director - Asia Pacific & Japan DELLAmit Gupta is the Director – Tax for Dell in Asia Pacific Japan (APJ) region. In this role, Amit is responsible for all

tax matters across Australia, New Zealand, Japan, Korea and Singapore. Prior to joining Dell, Amit was the Tax Leader (VP) at GE Capital in India where his responsibilities included managing taxes (corporate and indirect) for various legal entities and advising/implementing tax efficient structures for equity investments, cross-border funding/loans, leases, joint ventures and acquisitions. Amit has also worked as South Asia Tax Manager for Intel and inter alia managed transfer pricing audits, negotiations with Government on tax holidays, duty/tariff reductions and exemptions.

Murray Clayson Tax Partner FRESHFIELDS BRUCKHAUS DERINGERMurray is a tax partner in London. He specialises in international tax, finance

and capital markets taxation, corporate structuring, transfer pricing, banking and securities tax, asset and project finance, derivatives and financial products, particularly cross-border. He is a fellow of the Chartered Institute of Taxation, past-Chairman of the British Branch of IFA and a member of worldwide IFA’s Executive Committee, a member of the CBI’s main Tax Committee

and its International Taxes Working Group, and a member of the ICC’s Committee on Taxation.

Anthony Kerr Senior Director MAYER BROWNTony’s experience covers the full range of customs and international trade issues. He has extensive practical and

technical knowledge of customs legislation in China and in other countries across Asia. His primary focus has been on Customs valuation which is often impacted by direct tax transfer pricing where the use of inter-company prices based on direct tax transfer pricing has caused customs to question a related parties import values. He has played key roles in customs advocacy matters in China, Singapore, and the Philippines, assisting clients to minimise the impact of customs penalties and other revenue.

Eunice Kuo Partner DELOITTEEunice Kuo, a Tax partner of Deloitte China, is the National Leader for Transfer Pricing Service, in charge

of various transfer pricing and global tax structuring services. Eunice has 24 years experiences in providing tax service. Before entering Deloitte China, she was the operation leader of tax department and in charge account of transfer pricing and international tax services of Deloitte Taiwan. Eunice has many years of providing transfer pricing services, having worked for preparation of transfer pricing report, planning for cross-border transfer pricing risks on the association between enterprises, assisting enterprises to negotiate transfer pricing agreements and tax adjustments, and providing tax planning for process architecture of cross-border transactions.

Krishen Mehta Founding Director ASIA INITIATIVESKrishen Mehta is Founding Director of Asia Initiatives, a Senior Global Justice Fellow at Yale University, and a Senior

Advisor to Tax Justice Network in the UK. He is also a former PwC partner, and served in their NY, London,

and Tokyo offices. Krishen is on the Advisory Board of Aspen Institute’s Business and Society program, and has taught at the Fletcher School of Law and Diplomacy in Boston and at American University in Washington, DC.

Jesus Barrios Deputy General Manager Global TaxNISSAN MOTOR CO.Jesus Barrios is Deputy General Manager Global Tax at Nissan Motor Co. Ltd., leading the global tax planning

function and the APAC regional tax function. He has more than 15 years of experience working on tax matters for multinational companies based in the US and Japan, and has developed expertise in most areas of taxation including tax planning, tax reporting and tax compliance, transfer pricing, tax controversies and dispute resolutions.

Arun SethiDirector - Global Transfer Pricing and TaxNEPTUNE ORIENT LINESArun Sethi is currently Director of Global Transfer Pricing and Tax for Neptune Orient Lines (NOL), a global shipping

and container transportation company headquartered in Singapore. Arun’s current portfolio includes managing the group’s global Transfer Pricing practices as well as both international tax and indirect tax matters, with a specific focus on Asia Pacific and Europe. His background is in transfer pricing and international tax and he has worked in the Oil and Gas as well as Information Technology sectors. Prior to joining NOL, he was the Asia Pacific Transfer Pricing leader at IBM.

Himanshu Sinha Partner TRILEGALHimanshu Sinha has more than 18 years of experience in Direct Taxes. He has advised clients on entire range of direct

tax matters including International Tax, Transfer Pricing and Tax Controversies. He has represented large MNC clients before the Tax Tribunal, Authority for Advance Rulings and the higher courts with reported judgments to his credit. He has handled transactions involving complex tax issues, both cross-border and domestic. He has negotiated Advance Pricing Agreements with the

MEET 50+ TP LEADERS & ADVISERS INCLUDING...


Government on behalf of well-known global companies. Prior to joining Trilegal, he worked with a Big4 accounting firm. Himanshu spent more than a decade in the Indian Revenue Service (IRS) where he worked as Assistant Commissioner of Income Tax, Deputy Director (Investigation), Deputy Director (International Tax) and Transfer Pricing Officer.

Mr Brian Chiu Kwok Kit JPDeputy Commissioner INLAND REVENUE DEPARTMENT HONG KONGMr Chiu joined the Inland Revenue Department of the Hong Kong Special

Administrative Region of the People’s Republic of China after finishing his study in accountancy at Hong Kong Polytechnic University in 1983. He subsequently obtained his master degree in international accounting from City University of Hong Kong and his bachelor and master of law degrees from Peking University and University of London.He is now the Deputy Commissioner (Technical) of the Hong Kong Inland Revenue Department. His present portfolio includes tax treaties, transfer pricing, tax appeals, technical research, advance ruling. He also oversees the Individuals Tax Unit and the Profits Tax Unit. He is also a member of Hong Kong Institute of Certified Public Accountants, Institute of Chartered Accountants of England and Wales, Chartered Association of Certified Accountants, Taxation Institute of Hong Kong and CPA Australia.

Tobey Hill Asia Head of Tax CITIGROUPTobey is based in Hong Kong and heads the Asia regional tax group of 46 tax professionals for Citi. Her responsibilities

cover corporate tax planning, tax reporting, tax advisory, transfer pricing and tax controversies for sixteen Asian countries ex- Japan. She also coordinates and advises on the US tax aspects of various business transactions and restructurings. Prior to joining Citigroup in 2010, Tobey’s worked as a Tax Associate at a NJ-based law firm, a Consultant at AT&T in tax controversies, a US and International Tax Manager at Atlas Copco North America and a Tax Manager at Deloitte & Touche.

Fabrizio Lolliri European Director of Transfer Pricing HOGAN LOVELLSFabrizio joined Hogan Lovells in 2013, he has extensive industry experience which is coupled with well-grounded “Big

4” training and entrepreneurship. He has a background in science and engineering, which allowed him to make the transition to transfer pricing first as an economist at Deloitte and then KPMG. Fabrizio then became the Group Head of Transfer Pricing for FranceTelecom and Orange. Fabrizio featured in the Top 40 Under 40 in 2012 and is a published author of the TP books for 2013 and writes regularly for the Tax Journal. Fabrizio’s portfolio of clients includes Global 1000 and FTSE 100 multinationals.

Christopher Newman Managing Director DUFF & PHELPSChris Newman has approximately 18 years of transfer pricing and supply chain advisory experience working

in the US, Japan and Singapore. He has significant experience covering intangibles transactions including buy-in / buy-out payments for acquired and developed technologies, marketing intangibles and calculating cost-share payments. Chris has been engaged on projects for FIN 48 reporting, M&A due diligence, calculating and documenting complex service fee charges and controversy. Chris was most recently the Japan Inbound Practice Leader for a Big 4 firm. Chris was in charge of coordinating and providing transfer pricing and supply chain advisory for foreign MNCs with significant Japan transactions. He has been the lead Japan advisor for managing and negotiating unilateral and bilateral APAs for MNC’s across a range of industries including high technology, medical instruments and energy. His regional Asia Pacific supply chain experience includes advice on feasibility, design, potential exit tax costs, business purpose, entity conversions for function and risk profiles, setting profit targets, analyzing marketing intangibles and evaluating controversy strategies.

Annie PanAsia Pacific Tax DirectorRELX GROUPAnnie Pan is a tax professional with over 15 years’ experience in international tax (8 years with Global Fortune 500

MNCs and 7 with Big4 firms in Australia, providing tax advice to ASX 100 corporate clients). Annie is currently Asia Pacific Tax Director with RELX Group (formerly Reed Elsevier Group). Her role covers tax oversight function to tax compliance, tax advisory, tax compliance and tax planning for over 100 entities for four business segments in Asia-Pacific. She is also responsible for transfer pricing and other cross-border transactions, as well as M&A/Business Restructurings as part of her role with different divisions across APAC. Annie also lectures on Australian Taxation Law at James Cook University’s Singapore Campus.

S. P. Singh Senior Director; Transfer Pricing DELOITTES. P. Singh, who is presently a Senior Director with Deloitte in India, is an Ex-IRS Officer with more than two decades

of experience in the Indian Revenue Service. He functioned at various positions in the Service. Apart from others, he was posted as Deputy Secretary (Foreign Tax Division) in the Central Board of Direct Taxes, Ministry of Finance, Director of Income Tax (International Taxation), and Commissioner of Income Tax (Appeals).While working as Deputy Secretary, he was involved in formulating the Government’s policy regarding taxation of non-residents. He participated in negotiation of tax treaties with more than 30 countries and took part in Mutual Agreement Procedures. He was a Member of the Expert Group on Transfer Pricing constituted by the Ministry of Finance. The report was used for formulating transfer pricing regulations in India. As Director of Income Tax (International Taxation) he was responsible for income tax audit of the cases of multinational and other foreign companies. He represented the Income Tax Department before the Authority for Advance Rulings in several cases. Presently he heads transfer pricing teams in Delhi office.

Adnan Begic Regional (APAC) Transfer Pricing Manager MICHELIN ASIA PACIFICAdnan has 8 years of Transfer Pricing (TP) experience having worked in New

Zealand and Singapore as TP advisor in Big 4 and in-house TP Specialist in an MNC. Adnan has significant experience preparing multi-jurisdictional transfer pricing planning and documentation projects for companies across a diverse range of industries, including: oil & gas, retail, healthcare, pharmaceutical, automotive, construction, shipping, IT, technology, logistics, food & beverage, apparel, consumer electronics and fast moving consumer goods. Adnan has been involved in many APAs with the Inland Revenue Authority of Singapore and other revenue authorities in Australia, UK, Japan, New Zealand and Korea.

Rishabh Sawansukha Vice President - Taxation SNAPDEALRishabh Sawansukha is currently VP taxation for Snapdeal, India’s largest online marketplace. He has

15 years’ experience in managing both Direct and Indirect Tax (Planning, Litigation, Compliance, Audit & Assessments) in multiple tax Jurisdictions in leading Indian, European & American multinational companies. Prior to joining Snapdeal in July 2015, Rishabh was National Head of Taxation for Hindustan Coca-Cola. As part of his role he was responsible for State, Central and local tax planning, industrial incentive, tax review of contracts, special projects in supply chain & procurement, ERP stabilization, customs, Foreign Trade policy, investigations, Pan India litigation, advisory, and compliance. He also provided counsel to VP Tax and acted as key facilitator for integrated tax management, risk assessment, and leveraging on tax opportunities and optimization for 24 factories, 9 manufacturing locations and host of depots, managing US$ 2 Billion operations from tax perspective of world’s most famous brand.

... and many others to be announced

MEET 50+ TP LEADERS & ADVISERS INCLUDING...

10

TP MINDS ASIA 2015Day 1

3 November 2015

08:30 Registration & Coffee

08:55 Chairman’s Opening Remarks Jacques van Rhyn International Tax and Transfer Pricing Partner DELOITTE

Latest Policy Developments

09:00 Latest Developments at UN Level n The role of the UN in Transfer Pricing n Past, present and future of UN “norm development” in light of the Addis Ababa conference n An update on the UN Transfer Pricing Manual n Working collaboratively with other organisations

Ilka Ritter Associate Expert International, Tax Cooperation; Financing for Development Office UNITED NATIONS

09:30 KEYNOTE SPEECH BEPS- Multilateral and Unilateral Developments: An Australian Perspectiven BEPS Action Plan developmentsn The APA system in Australia andn Unilateral initiatives such as the Multinational Anti-Avoidance Law

Mark Konza Deputy Commissioner AUSTRALIAN TAXATION OFFICE

10:00 The Changing TP Policy Landscape – Insights from Key Policy Makersn Unilateral actions by governments - Will BEPS hold together or will unilateral action tear the

consistency of global tax principles apart?n Will BEPS require MNEs to change their business models and if so at what cost?n What steps can taxpayers take to ensure they obtain certainty in their tax positions?n The BEPS focus: Complying with the arm’s length principle or low tax jurisdictions?

Moderator:Jacques van Rhyn International Tax and Transfer Pricing Partner DELOITTE

Panellists:

Ilka Ritter Associate Expert International, Tax Cooperation; Financing for Development Office UNITED NATIONS

Mark Konza Deputy Commissioner AUSTRALIAN TAXATION OFFICE

Mr Brian Chiu, JP Deputy Commissioner INLAND REVENUE DEPARTMENT (Hong Kong)

Kriti Velji Transfer Pricing Advisor INLAND REVENUE DEPARTMENT (New Zealand)

10:50 Coffee & Networking



Managing Transfer Pricing Risk, BEPS & CBCR

11:10 BEPS Pledge for Transparency – How is it Impacting our Documentation?n BEPS lead to a quantitative growth of the documentation - Documentation requirement is set as a principle - Quantity of information to provide has gone up (action 12, action 13 -> CbCR)n Content of the documentation is changing - Focus on substance (action 9) - Re-characterization/reconstruction (action 10)n What does it really mean for us? - Documentation needs more resources and attention - Documentation needs to be thought through in an audit defense mindset (we are under perpetual audit!)

Jean-Louis Barsac Group Transfer Pricing and APAC Tax Director ALCATEL-LUCENT

11:40 Transparency, Exchange of Information & The Morality Debate n Where should we draw the line?n Should MNCs be expected to abide by a tax morality standard?n If so, who should be responsible for upholding that standard?

Panellists:

Sam Sim Transfer Pricing GEO Leader Asia-Pac & Japan IBM

Amit Bhalla Vice President, Tax & Customs – APAC SCHNEIDER ELECTRIC

Krishen Mehta Founding Director ASIA INITIATIVES

Ketan Madia South East Asia Head of Tax GENERAL ELECTRIC

12:15 INDUSTRY CASE STUDY Reconsidering the Post-Apocalyptic World of BEPS - Documentation Requirements & Disclosuresn Objectives of Documentation Requirementsn Three-Tiered Approachn Deep detail of MNE’s operations in a particular countryn Controversy and Alternative Dispute Resolution

Scott Campbell Global Transfer Pricing Manager FMC TECHNOLOGIES

12:50 Lunch & Meet the Speaker Lunch Tables

14:00INDUSTRY PANEL Managing Transfer Pricing Risk after BEPS & CbCRn Current BEPS and CBRC risksn Lessons from EU State Aid controversyn Potential risks to the Board, audit committee and auditorsn Practical risk minimisation strategies

Panellists:

Adnan Begic Transfer Pricing Manager, Asia-Pacific MICHELIN

Jean-Louis Barsac Group Transfer Pricing and APAC Tax Director ALCATEL-LUCENT

Tobey Hill Asia Head of Tax CITIGROUP

Jesse Kavanaugh Tax Director, Greater Asia Region INTEL SEMICONDUCTOR


14:40 INDUSTRY CASE STUDY MNCs TP Risk management in China’s Evolving TP Landscapen Evolving TP landscape in Chinan Tax authority’s focal points on MNCs tax administrationn Post-remediation or prior risk control?n Monitoring and risk control

Duo Wu Tax Director SIEMENS

15:10 Afternoon Refreshments

15:30INDUSTRY PANEL Taking the Pulse of the TP Audits Environmentn Hot Transfer Pricing issues raised by tax authorities in this Regionn Approaches for dispute resolution among AP countriesn Trend of tax authorities to introduce BEPS concepts in TP auditsn Role of transfer pricing documentation in TP audits

Moderator:Eunice Kuo Partner DELOITTE

Panellists:

Jackie Chan APAC Tax Director LEAR CORPORATION

Ravi Lakdawala Head of Transfer Pricing and International Tax BAYER

Amit Bhalla Vice President, Tax & Customs – APAC SCHNEIDER ELECTRIC

Terence Yuen Head of Tax, Asia Pacific BP

16:10INDUSTRY PANEL APAs – Latest Developments & Future Outlook for Asia n The current APA landscapen Impact of BEPS on the future of APAsn Will unilateral actions by countries in Asia make it more challenging for taxpayers to comply?n APAS in major emerging markets – Experiences in India, China and other high growth regionsn Best practice in managing APA processes globally

Panellists:

Chang Lee Head of Transfer Pricing, Asia ex-Japan NOMURA INTERNATIONAL

Peter Nieboer Senior Tax Manager APAC ASML

Amit Gupta Tax Director DELL

Patrick Connolly Senior Tax Director – Asia JABIL CIRCUIT


16:50 INDUSTRY PANEL Low Value-Adding Intragroup Servicesn BEPS discussion draft on Action 10 – Low value adding servicesn Low or high value? How to identify routine versus non-routine servicesn Contract R&D – Low value or high value in the context of IP ownership?n Effects of Action 10 on management fees. Mark-up versus allocation.n How will tax authorities react to Action 10? How to identify potential risk on low value adding services

Moderator: Fabrizio Lolliri European Director of Transfer Pricing HOGAN LOVELLS

Panellists:

Vatika Bhatnagar Transfer Pricing Manager AIRTEL

Adnan Begic Transfer Pricing Manager, Asia-Pacific MICHELIN

Frank Shao Head of Tax MERK

Dinesh Agrawal Senior Transfer Pricing Manager- MENA HSBC

17:30 Themed Champagne Roundtables DiscussionsRound up the day with an informal small group chat. Champagne, networking and relevant discussions with industry peers on key hot topics!

18:00 TP Minds Welcome Drinks

Financial Services Profit Split

Reputational Risk CbCRTP Automation

Digital Economy

TP MINDS ASIA 2015Day 2

4 November 2015

08:00 BREAKFAST BRIEFING BEPS & Operational Transfer Pricing Led by:

08:45 Registration & Coffee

09:00 Keynote Speech Mr Brian Chiu, JP Deputy Commissioner INLAND REVENUE DEPARTMENT (Hong Kong)


09:30 Inside the Mind of a Tax Administrator! Understanding the Tax Authorities Position on Current TP Challengesn Current technical and practical issues facing tax authoritiesn Approaches to setting transfer pricing policy in a changing economic environmentn Practical insights into MAP and APAsn How are cases for enquiry, audit and litigation selected?n Transfer pricing aspects of the BEPS projectn UK “Google Tax” – The way ahead?n Questions from the floor

Moderator: S.P. Singh Partner DELOITTE

Panellists: Kriti Velji Transfer Pricing Advisor INLAND REVENUE DEPARTMENT (New Zealand)

Steven Tsui Senior Assessor HONG KONG INLAND REVENUE DEPARTMENT

Mark Konza Deputy Commissioner AUSTRALIAN TAXATION OFFICE (Australia)

...and other tax administrations to be announced

10:25 Coffee & Networking

The Broader Tax & TP Landscape

10:45 Critical Transfer Pricing Developments in Key South East Asia Jurisdictionsn Recent legislative or administrative practice changesn Documentation requirementsn Response to BEPS initiativen Fiscal authority activity/trends

Carlo Navarro Partner DELOITTE

11:30 INDUSTRY PANEL Asia Tax Challenges - Beyond Transfer Pricing n Customsn Indirect taxationn Tax treaties n Permanent establishmentsn GST (Goods & Service Tax) in Indian Other issues

Moderator: Morrie Cheng Head of Tax and Accounting, Asia SUN LIFE FINANCIAL

Panellists:

Rishabh Kumar Sawansukha Vice President - Taxation SNAPDEAL

Anthony Kerr Senior Director MAYER BROWN

Masako Hikota Manager of Taxes; Japan IBM


Zooming in on Intangibles & Comparability

12:15INDUSTRY PANEL Intangibles & Comparability Issues in Asia-Pacificn Hard to value intangibles – observations from industryn Working with imperfect comparablesn Applying the profit split method in practicen The role of funding intangiblesn Managing uncertainty in the new environment

Panellists:

Ravi Lakdawala Head of Transfer Pricing and International Tax BAYER

Luis Carrillo Transfer Pricing Director BUREAU VAN DIJK

Vatika Bhatnagar Transfer Pricing Manager AIRTEL

Duo Wu Tax Director SIEMENS

Annie Pan Asia Tax Director RELX GROUP

13:00 Networking Lunch with Speaker-Hosted Tables

14:10 THOUGHT LEADERSHIPValuation Issues in Transfer Pricing n Overview: Transfer pricing / tax valuations vs financial reporting valuations - Importance to APAC tax professionals - Valuation issues in audits - Impact of BEPS n Bridging the divide between transfer pricing and financial statement valuationsn Discount rates and forecasting in transfer pricing valuationsn The role of capital in profit splits and the value chain

Christopher Newman Managing Director, Transfer Pricing DUFF & PHELPS

Controversy Management & Dispute Resolution

14:50 INDUSTRY PANEL Transfer Pricing Controversy & Dispute Resolution – The View from Industryn Handling controversies around the world – What’s your strategy?n New Transparency – Master Files and Country by Country Reportingn Gathering data, managing affiliates’ responses, expediting resolutionn Selection of venue – Local, MAP, APA, Arbitration?n Harmony with Customs, VAT, and other seemingly unrelated controversies

Moderator: Himanshu Sinha Partner TRILEGAL

Panellists:

Scott Campbell Global Transfer Pricing Manager FMC TECHNOLOGIES

Jesus Barrios Deputy General Manager Global Tax NISSAN MOTOR CO.

Terence Yuen Head of Tax, Asia Pacific BP

Arun Sethi Director - Global Transfer Pricing and Tax NEPTUNE ORIENT LINES

Amit Gupta Tax Director DELL


15:30 Afternoon Refreshments

15:45 Recent Asia-Pacific and International Case Law Developmentsn Review of the latest and most significant transfer pricing cases – Arguments of the tax authorities, decisions of the Courtsn Links to earlier cases and identification of key themes and questions arising n Implications for designing & documenting transfer pricing models – How to make your arrangements more challenge proof n The tax authority view – Opportunity for response by tax authority speakers

Murray Clayson Tax Partner FRESHFIELDS BRUCKHAUS DERINGER

Danny Beeton Managing Director, Transfer Pricing DUFF & PHELPS

Intragroup Financing & Services

16:30INDUSTRY PANEL Intragroup Financing – Practical ChallengesAs intragroup financing begins to share more TP lime lights both at the global and local levels, what are some of the challenges faced by those tasked with managing treasury TP in Asia Pacific today? Our panel speakers will discuss:n Credit Rating Challenges n CNY and other currencies n Group Synergies n Cash pooling TP maintenance n Guarantee Fees n Teaming with the Treasurers

Moderator: Patrick Cheung Partner DELOITTE

Panellists:

Vatika Bhatnagar Transfer pricing Manager AIRTEL

Dinesh Agrawal Senior Transfer Pricing Manager - MENA HSBC

Chang Lee Head of Transfer Pricing, Asia ex-Japan NOMURA

Annie Pan Asia Tax Director RELX GROUP

17:10 Transfer Pricing and Customs - Conflict of Interest & Valuation of Intangibles in Joint Development Plansn Valuation conflict - Journey from two extremes to achieve Arm’s Lengthn Joint product/prototype development with third party and cost apportioning from Customs perspectiven Embedded intangibles in hardware like software/updates/upgrades/patches - Condition of sale n Custom disputes and Interplay of local indirect taxesn Related party transactions - Approach reconciliation from a Customs and transfer pricing perspectiven Valuation Disputes - Long drawn process and Technical deficitn Post clearance custom audits - What are relevant TP records or import declarations?

Rishabh Kumar Sawansukha Vice President - Taxation SNAPDEAL

17:45 Close of Conference


Global Documentation & Country by Country Reporting

Hard to Value Intangibles & Cost Contribution Arrangements

PRE-CONFERENCE WORKSHOPS 2nd November 2015

Workshop 1 - 09:00 12:30 (Registration & Coffee from 08:30) Workshop 2 - 14:00 - 17:30 (Registration from 13:30)

Overview:The OECD as part of its Base Erosion and Profit Shifting (BEPS) Action Plan has made fundamental changes to the requirements for transfer pricing documentation that will impact most large multinationals beginning in 2016. The changes will have a significant impact on the way that companies prepare their transfer pricing documentation and the increased transparency caused by the changes could require companies to take additional risk mitigation actions. Our leading transfer pricing experts will discuss best practices to comply with the new requirements and the actions companies should consider now to mitigate the risks associated with the increased transparency of their transfer pricing policies and results as result of the changes.

Coverage Includes:n Impact of the new rules on your current documentation practicesn Issues and approaches in completing the country by country templaten Documentation and risk management strategiesn Countries adoption of the new rules

n Methods to reduce the increased administrative burden

Workshop Leaders:

Overview:Intangibles have always been difficult to value and it is even more difficult to value intangibles that are unique and have little correlation to the effort required to develop or enhance them. Furthermore, if multiple group entities contribute to the development of an intangible, it is important to align the contribution with the expected benefit in the future. Setting up a CCA is one vehicle, which can be used to share the burden of developing intangibles and enjoying its fruits. Various rules and guidelines provide insight on this matter, but mostly only at a very high level. The US regulations attempt to be more detailed, and one has to only look through those rules to understand the potential complexity in setting up a CCA. Valuing hard-to-value intangibles and setting up CCA, requires thorough understanding of the specific intangible at issue (effort required to develop, usefulness, commercial potential, life, and uniqueness), the context, plans for future maintenance/ enhancement of the intangible, and potential valuation approaches and their respective applicability).

Coverage Includes:n Evolution of the definition of intangibles and drivers of changes in such definitionn Typical methods of intangible valuation, and challenges in applying these approaches to hard-to-

value intangiblesn Valuation and CCA guidance provided by OECD, UN and a few countries through their respective

TP-related releases

n Two-to-three illustrative examples involving CCAs

Workshop Leaders: Anis Chakravarty Partner DELOITTE

Anis Chakravarty is a transfer pricing partner with Deloitte India. He brings considerable experience in advising companies on a number of issues related to economics, finance and transfer pricing. Anis specializes in IP planning, tax-aligned supply chain and implementation of cross-border structures. He is a co-leader of Deloitte’s Global Economists Network leading the intellectual property initiative in the Asia Pacific region having assisted a number of multinational companies realign and optimize their transfer pricing policy, benchmark returns for intellectual property and implement royalty rate structures.

Alan Shapiro Senior Advisor DELOITTE

Alan Shapiro is a Senior Advisor to Deloitte Tohmatsu Tax Co. He works with the organisation’s largest multinational companies to develop and implement transfer pricing strategies and is one of the its leading experts on cost sharing arrangements and the cross-border taxation of intangibles. He has represented clients in controversies with the IRS and in competent authority proceedings between US and foreign tax authorities. His industry experience includes the automotive, pharmaceuticals, electronic components, hi-tech, software, and consumer products sectors.

Jun Sawada Partner DELOITTE

Jun is a Partner of Deloitte Tohmatsu Tax Co., Transfer Pricing Group. After starting his career with Arthur Andersen in 1999, Jun has been advising both foreign and Japanese multinationals with various transfer pricing and cross-border taxation issues. Prior to his joining of Deloitte Tohmatsu Tax Co. in October 2013, he had also worked with Ernst & Young and White & Case. Jun has represented clients in various discussions with the Japanese tax authorities. He has defended companies under audit, assisted companies in their negotiations with tax authorities to obtain advanced approval of their transfer pricing (Unilateral/Bilateral APAs), and supported companies in domestic tax appeals.

Carlo Navarro Partner DELOITTE

Carlo is a Partner in Deloitte Southeast Asia who specializes in transfer pricing, international corporate re-structuring and planning, cross-border taxation, and tax-effective supply chain transformations. He covers or leads several transfer pricing practices in Southeast Asia. Before joining Deloitte in Singapore, Carlo has led transfer pricing and international tax practices of a Big 4 firm and has over 16 years of experience working in various jurisdictions in Southeast Asia as an International Tax and Transfer Pricing practitioner, giving him practical experiences in dealing with Tax Authorities of these countries.

18

PRE-CONFERENCE WORKSHOPS 2nd November 2015


Managing the TP Supply Chain of the Future Practical Measures in Assessing Transfer PricingRisk after BEPS

Workshop 3 - 09:00 – 12:30 (Registration & Coffee from 08:30) Workshop 4 - 14:00 - 17:30 (Registration from 13:30)

Overview:

New anti-avoidance rules such as the Diverted Profit Tax (“DPT”) in the UK will prompt businesses to both review their current supply chain arrangements and change the way feasibility for future arrangements is carried out. If substance is no longer enough to demonstrate the allocation of margin and proof of financial over tax benefits is required to determine whether a structure is artificial tax payers will have to invest more time and resources to run their benefit and tax risk feasibility model.

Coverage Includes:

n Brief introduction on the new changes in the legislation

n Weaknesses with current feasibility studies for supply chain

n Substance versus financial over tax benefits

n Case study looking at reassessing an existing supply chain structure in view of the new rules and looking at further optimising the structure by making an attempt to value financial over tax benefits to estimate risk of being caught by the DPT rules.

Workshop Leader:

Fabrizio Lolliri European Director of Transfer Pricing HOGAN LOVELLS

Fabrizio joined Hogan Lovells in 2013, he has extensive industry experience which is coupled with well-grounded “Big 4” training and entrepreneurship. He has a background in science and engineering, which allowed him to make the transition to transfer pricing first as an economist at Deloitte and then KPMG. Fabrizio then became the Group Head of Transfer Pricing for FranceTelecom and Orange. Fabrizio featured in the Top 40 Under 40 in 2012 and is a published author of the TP books for 2013 and writes regularly for the Tax Journal. Fabrizio’s portfolio of clients includes Global 1000 and FTSE 100 multinationals.

Overview:

The OECD’s Action Plan on Base Erosion and Profit Shifting (‘BEPS’) is a reflection of the spotlight placed on multinationals’ value chains by both tax authorities and wider stakeholder groups. Transfer pricing is a focus for both, increasing tax risk but also introducing an additional reputational risk for businesses. The greater transparency requirements arising from the BEPS Action Plan, in particular country-by-country reporting, tie directly into this rather than being simply an additional administrative step. This session will identify where transfer pricing risk has changed, consider effective steps to identify that risk and assess its impact on the business together with sustainable strategies to manage exposure and maintain the group effective tax rate.

Coverage Includes:

n Update on progress of OECD’s work on BEPS and related areas

n Process steps for assessing and addressing transfer pricing risk

n Managing the requirements of country-by-country reporting

n Achieving comfort on low risk transactions

n A proportionate response to high risk areas

n Making documentation work for you in the risk assessment process

19

supporters of TP MINDS ASIA 2015Lead Partner

Deloitte provides audit, tax, consulting, and financial advisory

services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and deep local expertise to help clients succeed wherever they operate. Currently Deloitte has over 600 dedicated Transfer Pricing professionals in 14 countries and across 33 locations in Asia Pacific. The team is a highly experienced group of professionals who have found innovative and practical solutions to provide successful outcomes for its clients. Deloitte has one of the best transfer pricing practices in the region through successfully servicing its global, regional and local clients with their documentation requirements, consulting advice and dispute resolution. When it comes to dispute resolution, Deloitte has a proven track record, with the aid of its professional experience, revenue authority relationships and know-how, in achieving outstanding transfer pricing outcomes, sometimes in seemingly impossible situations.

Gold Partners

Freshfields Bruckhaus Deringer LLP is one of the world’s

leading international law firms. Both its Tax and Dispute Resolution practices have market-leading reputations and are ranked number one in the main directories. Specialist practitioners from both these practice areas work together as a single Tax Disputes Group dealing with all kinds of international corporate tax disputes including an ever increasing number of complex transfer pricing cases. Recent transfer pricing cases have been determined on fine points of

law and the testimony of expert economists. Moreover tax authorities are recruiting their own economists and expressing a new determination to litigate when necessary. Taxpayers must find a way through increasingly detailed and often conflicting statutory transfer pricing codes in more and more tax jurisdictions. We have real transfer pricing expertise, delivering not only high quality international tax advice but also an equally expert level of economics know-how and dispute resolution experience and expertise. The result is a new offering for multi-national enterprises – a unique blend of economics, tax and dispute resolution skills with industry-specific commercial awareness. Whether your business faces the challenge of a transfer pricing dispute, or any other dispute relating to its international tax position, we can provide the solution.

The Complex Asset Solutions team of Duff &

Phelps provides supportable, transparent valuations of illiquid, difficult-to-value investments and complex securities to issuers, investors and regulators.As risk management requirements evolve, an increased focus on transparency and a lack of liquidity are transforming the way market participants quantify, manage and report the valuation and risk of derivatives.Duff & Phelps provides an expert team of quantitative analysts together with a library of cutting-edge valuation and risk models to assist its clients with their most pressing valuation needs. The Complex Asset Solutions team is backed by the resources of Duff & Phelps’ global platform, a leading independent provider of financial advisory and investment banking services.

Silver PartnersAbout Trilegal Trilegal is one of India’s leading law

firms, with expertise in the areas of mergers and acquisitions; strategic alliances & joint ventures; private equity & venture capital; energy and infrastructure; banking and finance; restructuring; capital markets; telecoms, media and technology; dispute resolution; regulatory; competition law; labour and employment; real estate; and taxation.

Mayer Brown Consulting (MBC) offers

customs and international trade advice to leading multinational companies seeking to maintain an advantage in the global marketplace. The team comprises experienced senior trade and customs professionals who assist clients integrate immediate- and long-term perspectives on local and international trade and customs regulations, WTO/FTA compliance and opportunities, as well as provide strategies designed to capitalize on opportunities and overcome market barriers. The team’s experience and network extend across the Asia-Pacific region. As a 100% wholly subsidiary of Mayer Brown, MBC also has access to more than 1,750 lawyers located in 22 locations throughout Asia, Europe and the Americas.

As experts in company information Bureau van Dijk can help you to

monitor your global operations and comply with country by country (CbyC) reporting. We have information on 140 million public and private companies, including extensive corporate ownership structures.The OECD’s report on the BEPS project Action 13 highlights the need to have robust data for transfer pricing compliance and better substantiated policies. Equip yourself for these challenges by using Bureau van Dijk’s TP Catalyst, a tool that simplifies the process of identifying comparables and produces the required analyses for transfer pricing reporting.To learn how you could benefit from TP Catalyst:

Visit: bvdinfo.com/transferpricing Call: +44 (0) 20 7549 5000Email: [email protected]

Hogan Lovells is a new law firm combining the breadth of business-oriented legal advice and high-quality service that clients have come to expect through working with its two founding firms

- Hogan & Hartson and Lovells. With over 2,500 lawyers operating out of more than 40 offices around the world, Hogan Lovells offers a unique, high quality transatlantic capability, with extensive reach into the world’s financial and commercial centres.

Bronze Partners

Thomson Reuters is the world’s leading source of intelligent information for

businesses and professionals. We combine industry expertise with innovative technology to deliver critical information to leading decision makers in the financial and risk, legal, tax and accounting, intellectual property and science and media markets, powered by the world’s most trusted news organization. Thomson Reuters’ Tax & Accounting is a leading global provider of integrated tax compliance and accounting information, software and services for professionals in accounting firms, corporations and government.For more information, go to www.thomsonreuters.com


Sponsoring TP Minds Asia, or even taking an exhibition stand, is a fantastic way of raising your company’s profile with an unrivalled number of industry professionals from across the region. Promote new and existing product and service offerings making use of this prestigious platform.

To learn more please contact David Gold on +44 (0)20 7017 7243 or e-mail [email protected]

PLEASE SELECT YOUR EARLY BIRD PACKAGEREGISTER BY 2 October 2015

REGISTER AFTER2 October 2015

n 3 DAY PACKAGE: Main Conference + 2 x Pre-Conference Workshops (please select below)

US$ 2,397 SAVE US$600

US$ 2,597 SAVE US$400

n 2.5 DAY PACKAGE:Main Conference + 1 x Pre-Conference Workshop (please select below)

US$1,998 SAVE US$400


n 2 DAY PACKAGE: Main Conference OnlyUS$ 1,599

SAVE US$200US$ 1,799

n 1 DAY PACKAGE: 2 x Pre-Conference Workshops Only (please select below)



n 0.5 DAY PACKAGE: 1 x Pre-Conference Workshop Only (please select below)

US$ 599 US$ 599

Please select up to 2 of the following Pre-Conference Workshops (2 November):

Morning workshops (09:00 – 12:30):n 1) Documentation and Country by Country Reporting (FKW52899w)n 3) Transfer Pricing Supply Chain Management (FKW52899x)

Afternoon workshops (14:00 - 17:30):n 2) Hard to Value Intangibles and CCA (FKW52899y)n 4) Assessing TP Risk after BEPS (FKW52899z)

If you are a senior in-house tax / TP professional please contact [email protected] to apply for free entry to TP Minds Asia.

HOW MUCH?

FKW528992 - 4 November 2015

Delegates are responsible for the arrangement and payment of their own travel and accommodation. For reduced rates on local hotels please see the accommodation page of our website.

WHEN AND WHERE

InterContinental Grand Stanford70 Mody Road Tsimshatsui East KowloonHotel reservations: +44 (0)20 7292 2320 Quote Special Reference Code: MNVDG

Unable to Attend - Event DocumentationNothing compares to being there – but you need not miss out. Don’t delay ordering today! Simply tick the box, complete your details and send the form along with payment. We regret Documentation Orders can only be processed on receipt of Credit Card details o TP Minds Asia 2015 - £299 + VAT @ 20%Documentation orders can only be processed on receipt of credit card details. To ensure we provide the highest level of security for your credit card details we are unable to accept such payments via email or fax, which ensures that these details are never stored on our network. To make payment by credit card: To make your payment on-line, please enter your credit card details in our secure payments website that you will use when making your documentation purchase via the event website (the event web address is near the top of the booking form). Alternatively call our customer service team on +44 (0) 20 7017 7790 or email your phone number with your documentation order to [email protected] and we will call you.

Email:[email protected]

Telephone:+44 (0) 20 7017 7790 Please remember to quote FKW52899

Fax:Complete and send this registration form to:+44 (0) 20 7017 7824

Payment should be made within 14 days of registration. All registrations must be paid in advance of the event

FOUR EASY WAYS TO REGISTER

THREE EASY WAYS TO PAY

The VAT rate is subject to change and may differ from the advertised rate. The amount you are charged will be determined when your invoice is raised. Savings include Multiple Booking & Early Booking Discounts. All discounts are subject to approval. Please note the conference fee does not include travel or hotel accommodation costs. 50% Discount for 3rd and subsequent delegates. All discounts can only be claimed at the time of registration and multi-booking discounts cannot be combined with other discounts that may be available (apart from early booking discounts which are available to everyone). We are happy to accept a replacement delegate for the whole event, however delegate passes cannot be spilt or shared between delegates under any circumstances. Conference code FKW52899

n BY CREDIT CARD To ensure we provide the highest level of security for your credit card details we are unable to accept such payments via email or fax which ensures that these details are never stored on our network. To make payment by credit card on-line, please enter your credit card details in our secure payments website that you will use when making your booking via the event website (the event web address is near the top of the booking form). Alternatively call our customer service team on +44 (0) 20 7017 7790.

n Cheque. Made payable to IIR UK Ltd. We will provide you details as to where to send the cheque once we receive your booking. Please write FKW52899 on the back of the cheque.

n By bank transfer: Full details of bank transfer options will be given with your invoice on registration.

VIP CODE

Please quote the above VIP code when registering

PERSONAL DETAILS

50% discount

1st Delegate Mr/Mrs/MsJob title/DeptCompanyAddress

TelephoneFaxEmailNature of BusinessBilling Address (If different from above address)

Yes! I would like to receive information about upcoming events by email. By giving you my email address I am giving Informa companies the permission to contact me by email

2nd Delegate Mr/Mrs/MsJob title/DeptCompanyAddress

TelephoneFaxEmailYes! I would like to receive information about upcoming events by email. By giving you my email address I am giving Informa companies the permission to contact me by email

3rd Delegate Mr/Mrs/MsJob title/DeptCompanyAddress

TelephoneFaxEmail Yes! I would like to receive information about upcoming events by email. By giving you my email address I am giving Informa companies the permission to contact me by email

Line Manager Mr/Mrs/MsJob title/DeptTelephone FaxEmail Booking Contact Mr/Mrs/MsJob title/DeptTelephone FaxEmail

Changes to the conference: IIR and IBC Finance may (at its sole discretion) change the format, speakers, participants, content, venue location and programme or any other aspect of the Conference at any time and for any reason, whether or not due to a Force Majeure Event, in each case without liability. Data protection: The personal information which you provide to us will be held by us on a database. You agree that IIR and IBC Finance may share this information with other companies in the Informa group. Occasionally your details may be made available to selected third parties who wish to communicate with you offers related to your business activities. If you do not wish to receive these offers please contact the database manager. For more information about how IIR and IBC Finance use the information you provide please see our privacy policy at: www.iiribcfinance.com/page/privacypolicy. If you do not wish your details to be available to companies in the Informa Group, or selected third parties, please contact the Database Manager, Informa UK Ltd, Maple House, 149 Tottenham Court Road, London W1T 7AD, UK. Tel: +44 (0)20 7017 7077, fax: +44 (0)20 7017 7828 or email [email protected] Incorrect Mailing: If you are receiving multiple mailings or you would like us to change any details, or remove your name from our database, please contact the Database Manager at the above address quoting the reference number printed on the mailing label. By completing and submitting this registration form, you confirm that you have read and understood the IIR and IBC Finance Delegate Terms and Conditions and you agree to be bound by them.

Web: www.ibc-events.com/TPAsia

TP MINDS ASIA 2015Main Conference: 3 - 4 November 2015, InterContinental Grand Stanford, Hong Kong FKW52899Pre-Conference Technical Workshops: 2 November 2015

TERMS AND CONDITIONS: Attendance at this conference is subject to IIR & IBC Finance Terms and Conditions at www.iiribcfinance.com/page/termsandconditions. Your attention is drawn in particular to clauses 6, 8 and 14 of IIR & IBC Finance Delegate Terms and Conditions which have been set out below: Cancellation Policy: You may cancel your registration in accordance with this Condition 6. You will receive a refund of your fees paid to IIR and IBC Finance (if any): (i) if you cancel your registration 28 days or more before the Conference, subject to an administration charge equivalent to 10% of the total amount of your fees plus VAT; or (ii) if you cancel your registration less than 28 days, but more than 14 days before the Conference, subject to an administration charge equivalent to 50% of the total amount of your fees plus VAT. IIR and IBC Finance regrets that the full amount of your fee remains payable in the event that your cancellation is 14 days or less before the Conference or if you fail to attend the Conference. All cancellations must be sent by email to [email protected] marked for the attention of Customer Services and must be received by IIR and IBC Finance. You acknowledge that the refund of your fees in accordance with Condition 6 is your sole remedy in respect of any cancellation of your registration by you and all other liability is expressly excluded.

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Documents

TP Minds Hong Kong Nov 2015