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Organisations need to be fully aware of the headaches of Transfer Pricing and the consequences of not adhering to country specific Transfer Pricing rules. This conference will aim to provide you with the ideal opportunity to listen for guidance from specialists, as well as easing the Transfer Pricing pressures you are faced with.

Transfer Pricing 2000 is organised and produced by SMi. We specialise and thoroughly research the Finance sector to pin areas which senior level executives, such as yourself, need to be informed of. SMi conferences are leading-edge business events offering delegates the opportunity to meet and network with senior industry figures.

Please register now to guarantee your place at this important conference.

Conference programme

8:30 Registration & Coffee

9:00 Chairman's Opening Remarks

Dr Rijkele Betten

Dr Rijkele Betten, Managing Editor, International Transfer Pricing Journal, International Bureau of Fiscal Documentation (The Netherlands), Tax Consultant, Swinkels Maas Verhorevoort

9:10 21ST CENTURY TRANSFER PRICING ISSUES

Dr Danny Beeton & Geoff Hopkins

Dr Danny Beeton & Geoff Hopkins, Head of Transfer Pricing Economics & Transfer Pricing Consultant, Grant Thornton International

  • Changes in the pattern of inter-company transactions
  • Changes in transfer pricing legislation
  • Changes in the approach of tax authorities
  • Changes in the approach of companies
  • Changes in the approach of business advisors
  • Implications of the changes for tax authorities, companies and business advisors
  • 9:40 OECD - TRANSFER PRICING

    John Neighbour

    John Neighbour, Head of Transfer Pricing Unit, OECD, (France)

  • Transfer pricing in the year 2000
  • Looking ahead to what is likely to happen in 2001 in regard to Transfer Pricing
  • 10:20 TRANSFER PRICING IN THE PHARMACEUTICAL INDUSTRY

    Anne Verrinder

    Anne Verrinder, Tax Manager, Pfizer

  • Transfer pricing and pharmaceuticals - industry specific challenges
  • Cross border research & development - sharing the costs
  • Arm's length pricing - comparability of pharmaceutical products
  • Purchasing active ingredients
  • The UK pharmaceutical marketplace - pricing constraints
  • Experts, internal audit and documentation
  • 11:00 Morning Coffee

    11:20 INTELLECTUAL PROPERTY PLANNING: THE HORROR STORIES

    John Henshall

    John Henshall, Director, Transfer Pricing, Deloitte & Touche

  • Acquisition planning
  • What’s in a name?
  • 12:00 TRANSFER PRICING IN THE US

    Paul J.R Bothamley

    Paul J.R Bothamley, European Tax Manager, Cargill

  • A brief summary of US transfer pricing rules
  • The differences between UK and US transfer pricing rules
  • Recent developments in the US
  • Intangible property
  • Documentation requirements and penalties
  • 12:40 Lunch

    14:00 THE EFFECT OF ECOMMERCE ON TRANSFER PRICING

    Gareth Green

    Gareth Green, Senior Consultant - Transfer Pricing, Ernst & Young

  • What type of e-business are there?
  • What transfer Pricing issues arise?
  • How can these issues be dealt with?
  • What planning opportunites arise from e-commerce?
  • 14:40 TRANSFER PRICING AND THE INLAND REVENUE

    Graham Black

    Graham Black, Assistant Director, International Division, Inland Revenue

  • An overview of Transfer Pricing and international transfer pricing
  • The impact of self assessment for transfer pricing
  • The changing face of legislation for Transfer Pricing
  • Advance Pricing Agreements
  • E-commerce
  • (OECD dimension)
  • 15:20 Afternoon Tea

    15:40 TRANSFER PRICING IN THE UK

    Steve Hasson

    Steve Hasson, UK Head of Transfer Pricing, PricewaterhouseCoopers

  • An overview of Transfer Pricing in the UK
  • Compliance with the revenue authorities
  • Self - assessment and documentation requirements for transfer pricing
  • Where a transfer pricing policy can help
  • Advanced pricing agreements - A method of resolving complex transfer pricing issues
  • APA’s and building good relationships with the relevant taxation bodies
  • 16:20 MANAGEMENT OF TRANSFER PRICING

    Marvin Rust

    Marvin Rust, Tax Partner, Arthur Andersen

  • Practical Management of Transfer Pricing
  • Transfer Pricing on a global level
  • Reconciling the expectations of the key authorities
  • Why intangibles should be a key focus - lessons to be learned from Case Law
  • 17:00 Chairman’s Closing Remarks and Close of Day One

    17:10 Drinks Reception for delegates and speakers

    8:30 Re-registration and Coffee

    9:00 Chairman's Opening Remarks

    Deborah Russell

    Deborah Russell, Publisher, International Tax, BNA International

    9:10 PREPARING A TRANSFER PRICING STUDY

    David C. Bukovac

    David C. Bukovac, Vice-President - Professional Services, Cross Border Solutions (USA)

  • Using in-house resources to collect and prepare documentation
  • How to employ third party databases to identify and evaluate comparables
  • How to perform the economic analysis to determine the arm’s-length price
  • Co-ordinating between relevant departments world-wide
  • Developing a global compliance and reporting solution
  • Implementing and training for global compliance
  • 9:40 TRANSFER PRICING ASPECTS OF ELECTRONIC COMMERCE: A NETHERLANDS PERSPECTIVE

    Dr Rijkele Betten

    Dr Rijkele Betten, Managing Editor, International Transfer Pricing Journal & Tax Consultant, International Bureau of Fiscal Documentation (The Netherlands) & Swinkels Maas V

  • Impact of tax treaty provisions and OECD works
  • Methods for determining the at arm’s length value of specific e-commerce products and services
  • Ecommerce life cycle considerations
  • 10:20 TRANSFER PRICING IN FRANCE

    Antoine Glaize

    Antoine Glaize, Head of International Tax - Tax audit department and APA Program, Ministry of Economics (France)

  • Reasons for addressing transfer pricing issues in France
  • A brief analysis of the French tax code for tax procedures
  • Transfer Pricing differences in France and across the channel
  • Time limits for adjustments and examinations for both French companies and European multinationals
  • The legislative document requirements for the French revenue service
  • Balancing Tax and commercial objectives
  • 11:00 Morning Coffee

    11:20 DISPUTE RESOLUTION AND EXCHANGE OF INFORMATION POWERS

    Paul Bowes

    Paul Bowes, Director of International Tax, Pannell Kerr Forster

  • APAs
  • Exchange of Information
  • Finance Act 2000 developments
  • 12:00 TRANSFER PRICING IN THE 21ST CENTURY

    Etienne Wong & David Saleh

    Etienne Wong & David Saleh, Partner & Senior Lawyer, Clifford Chance

  • How e-commerce is challenging traditional transfer pricing methodologies
  • What is the best transfer pricing strategy for dot-coms from a legal perspective?
  • Can transfer pricing e-commerce solutions be applied outside the realms of e-commerce?
  • How do you properly attibute income to permanent establishments involved in e-commerce?
  • Resolving the branch v subsidiary dilemma
  • 12:40 Lunch

    14:00 TRANSFER PRICING ISSUES FOR OIL AND GAS INDUSTRY

    Gerard Anderson

    Gerard Anderson, Tax Partner, Arthur Andersen

  • Sector Specific Aspects - the implications of transfer pricing in the oil and gas industry
  • Crude oil and other sales - Transfer Pricing Methodologies
  • Ring fencing
  • The risks to be managed by oil and gas companies
  • Lesson’s to be learnt from Transfer Pricing methodology from oil and gas companies
  • The future of transfer pricing in the oil and gas industry
  • 14:40 ARMS LENGTH PRICING FOR INTANGIBLES

    Dr Ted Keen

    Dr Ted Keen, Partner, KPMG

  • The differences between transfer pricing methodology for tangibles and intangibles
  • Calculating the arm’s length price and overcoming tax implications arising for Licensing
  • Technology transfers; Intellectual property; Cost sharing
  • 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?; Adjusting to new tax regulation
  • 15:20 THE CONSEQUENCES OF FAILURE TO COMPLY WITH LEGISLATIVE REQUIREMENTS

    Robert Schon

    Robert Schon, Corporate Tax Partner, Simmons & Simmons

  • The need to maintain an audit trail and appropriate 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
  • Making Transfer pricing work for us - avoiding penalties and double taxation
  • 16:10 Chairman's Closing Remarks and Close of Conference

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    WHAT IS CPD?

    CPD stands for Continuing Professional Development’. It is essentially a philosophy, which maintains that in order to be effective, learning should be organised and structured. The most common definition is:

    ‘A commitment to structured skills and knowledge enhancement for Personal or Professional competence’

    CPD is a common requirement of individual membership with professional bodies and Institutes. Increasingly, employers also expect their staff to undertake regular CPD activities.

    Undertaken over a period of time, CPD ensures that educational qualifications do not become obsolete, and allows for best practice and professional standards to be upheld.

    CPD can be undertaken through a variety of learning activities including instructor led training courses, seminars and conferences, e:learning modules or structured reading.

    CPD AND PROFESSIONAL INSTITUTES

    There are approximately 470 institutes in the UK across all industry sectors, with a collective membership of circa 4 million professionals, and they all expect their members to undertake CPD.

    For some institutes undertaking CPD is mandatory e.g. accountancy and law, and linked to a licence to practice, for others it’s obligatory. By ensuring that their members undertake CPD, the professional bodies seek to ensure that professional standards, legislative awareness and ethical practices are maintained.

    CPD Schemes often run over the period of a year and the institutes generally provide online tools for their members to record and reflect on their CPD activities.

    TYPICAL CPD SCHEMES AND RECORDING OF CPD (CPD points and hours)

    Professional bodies and Institutes CPD schemes are either structured as ‘Input’ or ‘Output’ based.

    ‘Input’ based schemes list a precise number of CPD hours that individuals must achieve within a given time period. These schemes can also use different ‘currencies’ such as points, merits, units or credits, where an individual must accumulate the number required. These currencies are usually based on time i.e. 1 CPD point = 1 hour of learning.

    ‘Output’ based schemes are learner centred. They require individuals to set learning goals that align to professional competencies, or personal development objectives. These schemes also list different ways to achieve the learning goals e.g. training courses, seminars or e:learning, which enables an individual to complete their CPD through their preferred mode of learning.

    The majority of Input and Output based schemes actively encourage individuals to seek appropriate CPD activities independently.

    As a formal provider of CPD certified activities, SMI Group can provide an indication of the learning benefit gained and the typical completion. However, it is ultimately the responsibility of the delegate to evaluate their learning, and record it correctly in line with their professional body’s or employers requirements.

    GLOBAL CPD

    Increasingly, international and emerging markets are ‘professionalising’ their workforces and looking to the UK to benchmark educational standards. The undertaking of CPD is now increasingly expected of any individual employed within today’s global marketplace.

    CPD Certificates

    We can provide a certificate for all our accredited events. To request a CPD certificate for a conference , workshop, master classes you have attended please email events@smi-online.co.uk

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