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Following on from the success of last year’s International Transfer Pricing II conference we are once again bringing together the international specialists within the Transfer Pricing field and tackling the issues that matter. International Transfer Pricing III offers a unique opportunity to hear from a leading international panel of speakers at the cutting edge of Transfer Pricing. This event gives you the opportunity to join the sector early and to strategically align your company for optimum success.

Conference programme

8:30 Registration and Coffee

9:00 Chairman's Opening Remarks

Philip Peacock

Philip Peacock, Group Tax Manager, Coats Viyella

9:10 DISPUTE RESOLUTION AND APAS

Paul Bowes

Paul Bowes, Director of International Tax, Pannell Kerr Forster

  • Mutual Agreement Procedures and Arbitration
  • The new APA regime in the UK
  • Factors to consider when making applications
  • Will size of organisation/transaction matter?
  • 9:45 THE REVENUES PERSPECTIVE

    Andrew Hickman

    Andrew Hickman, International Division, Inland Revenue

  • An Introduction
  • Mutual Agreement procedure , Arbitration and APAs in practice
  • Questions and Answers
  • 10:20 OECD - TRANSFER PRICING

    John Neighbour

    John Neighbour, Principle Administrator, OECD, (France)

  • Introduction to new guidelines for MAP APAs
  • Scope, background and eligibility for MAP APAs - including multilateral APAs
  • Guidelines for taxpayers - formulating the APA request, making the proposal to tax authorities and expediting the process
  • What you can expect from the tax authorities - reviewing and finalising the MAP APA, implementing it domestically, monitoring compliance and renewal conditions
  • 11:00 Morning Coffee

    11:20 CASE STUDY

    Philip Jones

    Philip Jones, Taxation Manager, Bank of Tokyo - Mitsubishi

  • How the UK laws stand on Transfer pricing
  • How the transfer pricing laws effect multinational companies cross border transactions?
  • Learning by mistakes - The implications of the new legislation on multinational companies
  • What does the future hold for multinational companies - do these companies realise and understand the penalties?
  • 12:00 NEW TRANSFER LEGISLATION

    Steve Hasson

    Steve Hasson, Partner Head of Transfer Pricing, PriceWaterhouseCoopers

  • The new regime
  • Self-assessment
  • The technical analysis
  • The implications for leading edge thinking
  • Issues and solutions
  • 12:40 Lunch

    14:00 CASE STUDY

    Mike Sufrin

    Mike Sufrin, Director of Tax, Rolls Royce

  • Balancing tax and commercial objectives
  • Compliance with revenue authorities
  • Does self - assessment and keeping documentation required for transfer pricing make more work for the tax department?
  • Where a transfer pricing policy can help
  • Advanced pricing agreements - A method of resolving complex transfer pricing issues
  • 14:40 TRANSFER PRICING IN FRANCE

    Antoine Glaize

    Antoine Glaize, Head of international Division for Tax Audit, Ministry of Economics (France)

  • Reasons for addressing transfer pricing issues in France
  • Time limits for adjustments and examinations for both French companies and European multinationals
  • The new documentation requirements for the French revenue service
  • 15:20 Afternoon Tea

    15:40 CASE STUDY

    Gerard Anderson

    Gerard Anderson, International Tax Advisor, International Tax Advisor

  • Sector Specific Aspects – the implications of transfer pricing in the oil and gas industry
  • Crude oil and other sales – Transfer Pricing Methodolgies
  • Ring fencing
  • The risks to be managed by oil and gas companies
  • 16:20 MANAGEMENT OF TRANSFER PRICING

    Marvin Rust

    Marvin Rust, Tax Consultant, Arthur Anderson

  • Should you adopt a global approach to Transfer Pricing?
  • Reconciling the expectations of the key authorities
  • Why intangibles should be a key focus – lessons to be learned from DHL v’ Internal Revenue Service
  • 17:00 Chairman’s Closing Remarks and Close of Day One

    8:30 Re-registration and Coffee

    9:00 Chairman's Opening Remarks

    Mandy Pachol

    Mandy Pachol, Group Tax Manager, ICL Computers

    9:10 A LOOK AT TRANSFER PRICING IN THE USA

    Donald Scherer

    Donald Scherer, Taxation Manager, Cross Border Solutions (USA)

  • The international response
  • Tax planning for complex cross-border business combinaions
  • The implications of just employing staff to manage multinationals' transfer pricing
  • How major changes in tax laws have come under the self-assessment procedures
  • The problems with multinational companies disclosing Advanced Pricing Agreements (APA's) in the USA
  • 9:40 DUTCH LAWS

    Harmen van Dam

    Harmen van Dam, Senior Tax Advisor, Loyens & Volkmaars, (Netherlands

  • Reasons for addressing transfer pricing issues
  • Changes introduced in The Netherlands and does it affect other countries?
  • Burden of Proof
  • Examinations and Adjustments for multinational companies
  • Interest rates on cross border loans
  • 10:20 21ST CENTURY TECHNOLOGY AND TAXATION

    Julian Hickey

    Julian Hickey, International Tax Advisor, Ernst & Young

  • How to measure electronic commerce – How can internet exchanges be taxed and how will it operate
  • The provision of services on the internet – How, what and why
  • Can tax authorities measure transactions that take place?
  • The impact on business transactions and effects on taxation
  • Electronic commerce – How will multinationals chart their way in unknown territory?
  • 11:00 Morning Coffee

    11:20 CONSEQUENCES OF THE NEW LEGISLATION

    Gareth Green

    Gareth Green, Senior Manager, Ernst and Young

  • The need to maintain large quantities of records to justify their intra-group cross border pricing
  • The loss of protection currently afforded by Revenue administrative process
  • Need for greater reliance on the Advanced Pricing Agreements
  • Penalties if companies get the pricing wrong – up to 100% of additional tax in some cases
  • Red flags and bear traps
  • Do multinational companies realise the implication of new legislation’s – are they ready?
  • 12:00 CASE STUDY

    John Bird

    John Bird, Deputy Taxation Director, Barclays Bank

  • How Transfer Pricing effects the Banking Industry
  • Tax Department v The Business Areas responsibility
  • Functional Analysis
  • Methodologies which are employed
  • Proposed Global Dealing Regulations v Arms length price
  • Balancing Tax and commercial objectives
  • 12:40 Lunch

    14:00 CASE STUDY

    Steve Cronin

    Steve Cronin, Tax Manager, Premier Oil

  • Legitimate profit-splitting methods within a multinational company
  • Tax planning and the implications for the future
  • The Impact on overseas investment
  • Monitoring administration and records for submission to the Revenue
  • The effects of the new transfer pricing legislation on the oil industry
  • 14:40 LEGAL IMPLICATIONS

    Stephen Edge

    Stephen Edge, Partner, Slaughter and May

  • Are more areas of the law likely to change?
  • A review of the most recent court cases with regard to transfer pricing
  • Learning by others’ mistakes, are multinational companies really learning?
  • Handling Inland revenue enquires and disputes
  • Setting up a good system for financially sound transfer pricing and covering yourself and your organisation
  • 15:20 Afternoon Tea

    15:40 TANGIBLES & INTANGIBLES

    Dr Ted Keen

    Dr Ted Keen, Head of Transfer Pricing Economist, KPMG

  • Calculating the arm’s length price and overcoming tax implications arising for Licensing Technology transfers
  • Finding comparable data to assign value and risk to intangibles as accurately as possible
  • How to apply current value and predict value growth of intangibles to ensure continued future compliance
  • What local guidance is available?
  • 16:20 CASE STUDY

    Peter Mason

    Peter Mason, Taxation Director, Smith Industries

  • Advanced pricing agreements and complying with revenue authorities
  • In-house format of transfer pricing returns at Smith Industries
  • Evaluating documentation and being prepared for self – assessment
  • Making Transfer pricing work for us – avoiding penalties and double taxation
  • Preparing and implementing the new tax regime Risks and functions in commercial principals
  • How much control can tax directors and managers have over the transfer pricing policy
  • 17:00 Chairman's Closing Remarks and Close of Conference

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