THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS …€¦ · THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS ON THE WEST COAST Inspiration 40+ Speakers 20+ Presentations

Main Conference: November 5-6 2019Workshops: November 7 2019San Francisco Marriott Union Square

THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS ON THE WEST COAST

Inspiration40+ Speakers20+ Presentations & Panels2 Workshops

Networking125 Attendees70% Corporate Delegates

The Region’s Leading Independent Transfer Pricing Forum

Norman WingenOECD

Brad ParkerINTEL CORPORATION

Joshua WallsAMGEN

Srini LalapetUiPATH

Bob GambinoAUTODESK

Lisa LiUBER

finance.knect365.com/tp-minds-west-coast/TP Minds @TPSummit

#TPWestCoast

2To register or for the latest information, please visit: finance.knect365.com/tp-minds-west-coast/ Tel: +44 (0) 20 7017 7790 Email: [email protected]

CONTENTS3 Programme at a Glance4 Meet 40+ TP Leaders, Advisers & Policy Makers7 Summit Day One10 Summit Day Two12 Post-Conference Worshops13 Supporters of TP Minds West Coast 2019

EVENT SCHEDULEMain Conference: 5-6 November 2019Workshops: 7 November 2019

SPONSORS AND EXHIBITORSLEAD PARTNER CO-PARTNER

GOLD PARTNERS

SILVER PARTNERS

ASSOCIATE PARTNERS

To register or for the latest information, please visit: finance.knect365.com/tp-minds-west-coast/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 3

TP MINDS WEST COAST 2019 PROGRAM AT A GLANCETUESDAY, NOVEMBER 15MAIN CONFERENCE, DAY 1

We kick of TP Minds West Coast with our keynote, Norman Wingen at the OECD who will be providing an insightful update on the latest developments at OECD level. Our global transfer pricing policy developments session will bring together speakers from the IMG, IFC and SUNAT to look a how international organizations and tax authorities are addressing transfer pricing in wake of BEPS 2.0. Further highlights for the day include the tax challenges of the digital economy, value chain analysis, and APAs!

Big Themes• Global Transfer Pricing Policy

Developments• Tax Challenges of the Digital

Economy• Risk, Governance & Transparency • Outstanding Issues with the BEAT

Regulations• Facilitating the Resolution of a

Bilateral APA

Key Speakers

Norman Wingen, OECDSpencer Stowe, IRSJoshua Walls, AmgenTerri Ziacik, MICROSOFTDotan Russo, CLOUDERADebora Correa Talutto, VERITAS

WEDNESDAY, NOVEMBER 16MAIN CONFERENCE, DAY 2

Day two of TP Minds West Coast starts with a look at controversy & dispute resolution, with perspectives on latest cases, and practical tips and best practice when faced with the possibility of a transfer pricing dispute. We then move on to our intangibles & comparability session, a key topic for West Coast businesses, eploring the current intangibles environment and latest policy guidance. Further key topics include recent EU State Aid decisions, transfer pricing & technology, and financial transactions.

Big Themes• Controversy & Dispute Resolution• Financial Transactions• Hard to Value Intangibles• EU State Aid Challenges• Transfer Pricing & Technology• M&A Transactions

Key Speakers

Brad Parker, INTELLisa Li, UBERSrini Lalapet, UiPATHPrapti Doshi, MICROSOFTCarla Ackley Cravalho, CISCOWalter Kollings, VISA

THURSDAY, NOVEMBER 17POST-CONFERENCEWORKSHOPS

Two highly interactive and technically sophisticated workshop sessions deigned to allow you to diver deeper into the critical aspects of Transfer Pricing.

Big Themes• War and Peace: Transfer Pricing in

the Modern Business World• Operational Transfer Pricing

Key Speakers

Theresa Kolish, KPMGSean Foley, KPMGBernhard von Thaden, KPMGDavid Unger, KPMGSaurabh Dhanuka, KPMGJuan Carlos Ceballos, GLOBONOMICS

4To register or for the latest information, please visit: www.ibc-events.com/tpamericas Tel: +44 (0) 20 7017 7790 Email: [email protected]

MEET 40+ TP LEADERS, ADVISERS & POLICY MAKERS Sharron Keegan Tax Director ROKU

Terri Ziacik Director, Transfer Pricing MICROSOFT

Jessie Coleman Tax Office Lead IFC

Srini Lalapet Global Lead for Transfer Pricing UIPATH

Ningyue Wang Transfer Pricing Senior Manager INTEL

Enrique Rayon Director of Transfer Pricing VIASAT

Joshua Walls Transfer Pricing Director AMGEN

Norman Wingen Transfer Pricing Advisor OECD

Carla Ackley Cravalho Senior Global Tax & Customs Manager CISCO

Bob Bamsey Manager ‚Äì Global Transfer Pricing Services RSM

Debora Correa Talutto SeniorTransfer Pricing Manager VERITAS

Rebel Curd Vice President, Practice Leader of Transfer Pricing CHARLES RIVER ASSOCIATES

Steven Davis Principal, Tax - Value Chain Management KPMG

Saurabh Dhanuka Managing Director, Transfer Pricing Services KPMG

Steven Dixon Member MILLER & CHEVALIER

Prapti Doshi Senior Manager, Transfer Pricing MICROSOFT

Jamie Eagan VP of Tax Product Management LONGVIEW

Sean Foley Head of Global Transfer Pricing Dispute Resolution KPMG

Bob Gambino Senior Tax Manager, Transfer Pricing AUTODESK

Robin Hart Principal CHARLES RIVER ASSOCIATES

Cory Hillier Senior Counsel IMF

Brett Kass Senior Manager - Transfer Pricing & Planning AIRBNB

CLARK CHANDLER Partner VALENTIAM

Juan Carlos Ceballos Transfer Pricing Partner GLOBONOMICS


Jon Jenni Senior Director and West Region Leader, Transfer Pricing RSM

Fred Johnson President JOHNSONTP

Theresa Kolish Managing Director, Transfer Pricing Services KPMG

Walter Kolligs Vice President - Head of International Tax VISA

Mark van Casteran Partner LOYENS & LOEFF

Lisa Li Director, Transfer Pricing and Special Projects UBER

Aurelio Massimiano Partner MAISTO E ASSOCIATI

Sri Nagarajan Principal, Transfer Pricing Services KPMG

Burcin Nee Principal, Transfer Pricing Services KPMG

Jack O’ Meara Principal, Washington National Tax‚ÄîTransfer Pricing KPMG

Anne Oliver Finance Director, Global Tax SKYSCANNER

Fernando Becerra O´Phelan Manager of Transfer Pricing Operations SUNAT

Brad Parker Head of Global Transfer Pricing INTEL CORPORATION

David Paul Chief Tax Counsel AMERICAN HONDA MOTOR COMPANY

Loren Ponds Member MILLER & CHEVALIER

Clark Chandler Partner VALENTIAM

Dotan Russo Tax Director CLOUDERA

Spencer Stowe Team Leader IRS

Jim Toomey Vice President, Global and Regional Accounts S&P GLOBAL MARKET INTELLIGENCE

David Unger Managing Director, Transfer Pricing Services KPMG

Paul Fields Director, Transfer Pricing Services KPMG

Deborah Van Horn Director of Tax MATRIXX SOFTWARE

Bernhard von Thaden Principal, Transfer Pricing Services KPMG

Mark Madrian Partner VALENTIAM

Lisa Youel VP Tax EXPEDIA


DAY 1 | NOVEMBER 5, 201908:30 Registration & Coffee

09:00 Chair’s Opening Remarks Bernhard von Thaden Principal, Transfer Pricing Services KPMG

09:10Latest Developments at OECD LevelHow are the international organizations and Tax Administrations addressing transfer pricing and the evolving international tax landscape, including BEPS and other developments, and where do they expect them to develop in the future


09:50

Global Transfer Pricing Policy DevelopmentsHow are the international organizations and tax authorities addressing transfer pricing and the evolving international tax landscape, including BEPS 2.0 and other developments, and where do they expect them to develop in the future






10:30

Quickfire Round: Ask The Policy MakersDon’t miss your opportunity to put your questions directly to our panel of leading tax authorities and policy makers. They will try to address as many of your questions as possible during this session and we would like to remind you these can be submitted in a number of ways. You can:• Ask for the microphone and put your questions live to our panel on stage• Submit a question through our event app and have this answered in real time• Tweet us your question using the hashtag #TPWESTCOAST19• Email a complex question in advance to [email protected] so this can be addressed by our experts at the event having given it careful consideration in the run-up to the event






10:50 Morning Coffee


11:10

The great arm’s length debateThe role of the arm’s length principle in the current international tax environment• Interactions with other areas of international taxation - diverted profits tax - financing arrangements - corporate interest restriction - impact of CbCR data - interaction and tension with indirect taxes - the relationship with permanent establishment - employment tax issues• How does our approach as transfer pricing practitioners flex in response?

Sharron Keegan Tax Director ROKU

Bob Gambino Senior Tax Manager, Transfer Pricing AUTODESK

Anne Oliver Finance Director, Global Tax SKYSCANNER

Jon Jenni Senior Director and West Region Leader – Transfer Pricing RSM

11:50

Tax Challenges of the Digital Economy & BEPS 2.0Latest Policy Developments Worldwide. An exploration and discussion of the OCED”s programme of work on BEPS 2.0. and the enactment of the inconsistent unilateral measures around the globe. What do these policies mean for businesses and how should MNEs be responding?

Jack O’ Meara Principal, Washington National Tax—Transfer Pricing KPMG

Srini Lalapet Global Lead for Transfer Pricing UiPATH

Jim Toomey Vice President, Global and Regional Accounts S&P GLOBAL MARKET INTELLIGENCE

Debora Correa Talutto SeniorTransfer Pricing Manager VERITAS

12.30 Lunch - sponsored by

13:30

Transfer Pricing Risk, Governance & Transparency.• Managing investor relations and questions• Tax under the spotlight; corporate reputation management• Relationships with the tax authorities• Can internal audits drive change within a business?• The ICAP programme• What does it mean to be audit ready in the current environment?

Robin Hart Principal CHARLES RIVER ASSOCIATES



14:15TCJA - Outstanding Issues with the BEAT RegulationsThis session will provide an overview of the substance of the final BEAT regulations and discuss the issues that were not (and ostensibly, could not be, due to lack of regulatory authority) addressed in the regulations and the implications for taxpayers.


Lisa Youel VP Tax EXPEDIA


15:00 Afternoon Coffee



15:20The Second Wave of TP Documentation & CbCR• Global perspectives on experiences, challenges and successes• How are tax authorities using this data?• Are we seeing more audits and enquiries as a result of CbCR submissions?

Enrique Rayon Director of Transfer Pricing VIASAT

Joshua Walls Transfer Pricing Director AMGEN

Mark Madrian Partner VALENTIAM


Rebel Curd Vice President, Practice Leader of Transfer Pricing CHARLES RIVER ASSOCIATES

16:05

Value Chain AnalysisValue Chain Analysis (VCA) – Why all the Hype? From documentation to DEMPE, this panel will explore the challenges of conducting a meaningful analysis in a dynamic market place. How and why should a tax department incorporate a VCA into its transfer pricing and tax planning. What are the implications of a VCA for controversy: how are Tax Authorities using VCAs in audits, advance pricing agreements, and mutual agreement proceedings. What are the practical ways in which companies can balance the increased external demands for transparency with internal strategic imperatives?

Theresa Kolish, Managing Director, Transfer Pricing Services, KPMG

Jack O’ Meara Principal, Washington National Tax—Transfer Pricing KPMG

Paul Fields Director, Transfer Pricing Services KPMG

16:45

Facilitating the resolution of a Bilateral APA• What makes a bilateral APA unique?• Proposed TPM – strategic considerations• Understanding each stakeholder’s goal(s)• Impasse during competent authority negotiations – what next?

Fred Johnson President JohnsonTP

David Paul Chief Tax Counsel AMERICAN HONDA MOTOR COMPANY

Spencer Stowe Team Leader IRS

Clark Chandler Partner VALENTIAM

17:30 Chair’s Closing Remarks & Drinks Reception hosted by


DAY 2 | NOVEMBER 6, 201908:30 Registration & Coffee

09:00 Chair’s Opening Remarks David Unger Managing Director KPMG

09.10Financial TransactionsA presentation on the common issues with Treasury related intercompany flows, current priorities for Treasury Teams, and how TCJA and recent OECD developments can shape the relationship between tax and treasury.

Burcin Nee Principal, Transfer Pricing Services KPMG

09.50

Intangibles and ComparabilityA review of the current TP landscape for Intangibles, with a focus on difficult issues arising from the US rules, the OECD, and local country regimes. What are the considerations and experiences around IP onshoring transactions and IP acquisitions/integration, and how should the DEMPE analyses influence these transactions? How are Profit Splits,including the APA Functional Cost Diagnostic Model being used to evaluate intangible transactions? How and when can market-based benchmarks and comparable transactions be used for intangibles transactions?

Sri Nagarajan Principal, Transfer Pricing Services KPMG

Deborah Van Horn Director of Tax MATRIXX SOFTWARE

Lisa Li Director, Transfer Pricing and Special Projects UBER

10:35 Morning Coffee

10.55

The move towards automation: transfer pricing & technologyDeveloping an effective automation solution for your tax function• Designing a successful tax technology strategy • Improving the consistency of compliance processes• Automation and streamlining of tax processes

Srini Lalapet Global Lead for Transfer Pricing UiPATH

Ningyue Wang Transfer Pricing Senior Manager INTEL

Jamie Eagan VP of Tax Product Management LONGVIEW

Prapti Doshi Senior Manager, Transfer Pricing MICROSOFT

11:45

Transfer Pricing Controversy and Dispute Resolution• The current landscape on the West Coast• Effectively managing TP audits• Best practice for effectively resolving TP disputes

Aurelio Massimiano Partner MAISTO E ASSOCIATI



Brad Parker Head of Global Transfer Pricing INTEL CORPORATION


12.35 Lunch


12.35

EU State Aid update: Setback for European Commission (EC) in their “War on Tax Deals”• EC failed to demonstrate the existence of an advantage in favour of Starbucks - where did it go wrong for the EC?• The EUGC upheld the EC’s Fiat decision – why was the decision in Fiat different than in Starbucks?• EC’s investigations in other tax deals are still ongoing, e.g. Ikea, Nike, Huhtamäki: what are the consequences of the

recent decisions for these pending cases?• What can we expect from the EC with respect to any future cases?

Mark van Casteran Partner LOYENS & LOEFF

14:15 Industry case study: Trade Wars Carla Ackley Cravalho Senior Global Tax & Customs Manager CISCO

14:45 Afternoon Coffee

15.05Transfer pricing & M&A transactions• Integration of intangible assets• Acqui-hires & US tech dominance• Intangible ownership structures


Walter Kolligs Vice President - Head of International Tax VISA

Brett Kass Senior Manager - Transfer Pricing & Planning AIRBNB

Bob Bamsey Manager – Global Transfer Pricing Services RSM

15.55 Chair’ Closing Remarks and Close of Main Conference

CPE POINTS AT TP MINDS WEST COAST 2019 Recommended CPE Credits:

• 20 CPE Credits (two main conference days + all post conference workshops)

• 14 CPE Credits (two main conference days only)

• 6 CPE Credits (post-conference workshops)

TP Minds West Coast 2019 will cover the latest Transfer Pricing developments globally as well as those impacting Silicon Valley based corporations. The summit will also look at the wider International policy developments relating to the tax treatment of complex Transfer Pricing (TP) transactions that global multinational enterprises operating globally deal with, in an increasingly regulated environment. Industry speakers will share practical experiences and case studies with their peers and professional advisers will contribute with valuable technical information in the most complex areas of TP. Learn more at:https://finance.knect365.com/tp-minds-west-coast/cpe-points


Workshop A (08:30 Registration, 09:00 - 11:30)

Workshop A: War and Peace: Transfer Pricing in the Modern Business WorldOverview:An interactive case study workshop exploring transfer pricing from value chain to controversy defense. Workshop participants will engage in a value chain and DEMPE analysis and review and consider best practices for creating a comprehensive and consistent narrative for Master Files, Local Files, and other documentation. The workshop will also explore strategies and best practices for handling controversy on multiple fronts, particularly in light of the increased transparency between tax authorities.

Workshop B (11:45 -14:30, Working Lunch Included)

Operational Transfer PricingOverview:Session details to follow

POST-CONFERENCE WORKSHOPS November 7, 2019

Workshop Leaders:



Bernhard von Thaden Principal, Transfer Pricing Services KPMG

David Unger Managing Director KPMG

Saurabh Dhanuka Managing Director, Transfer Pricing Services KPMG

Workshop Leaders: Juan Carlos Ceballos Transfer Pricing Partner GLOBONOMICS


SUPPORTERS OF TP MINDS WEST COAST 2019In today’s post BEPS world, transfer pricing has been transformed. Companies face new reporting and information sharing challenges, and the need for a global narrative. KPMG firms can help companies develop and implement economically supportable transfer prices, document the policies and outcomes, and respond to questions raised by the tax authorities. Professionals in the KPMG’s Global Transfer Pricing Services practice helps clients make difficult decisions about prioritizing limited resources every day. Navigating the proliferation of BEPS-driven requirements with a finite budget requires careful risk tiering and consideration with a conjoined focus on process and technology. With KPMG’s global network providing access to transfer pricing professionals around the world, the team is well-equipped to provide the local experience and global context that multinationals need in today’s environment.

www.valentiam.com

www.crai.com

LEAD PARTNER

GOLD PARTNER

Loyens & Loeff has an experienced transfer pricing team that provides transfer pricing related advice in the Netherlands, Belgium, Luxembourg and Switzerland. As transfer pricing is intertwined with most tax issues, we fully integrate transfer pricing expertise with our various tax and legal practices. The team consists of experts in corporate income tax, value added tax, customs duties, commercial contracts, controversies, litigation and state aid procedures. With this expertise we assist clients in planning, documentation, tax audits, negotiations with (international) tax authorities in uni-, bi- and multilateral APAs, litigation and state aid procedures.

GOLD PARTNERS


A world leading provider of audit, tax and consulting services to entrepreneurial growth-focused organisations and multinationals globally. As an integrated team, we share skills, insight and resources, as well as a client-centric approach that’s based on a deep understanding of your business. Our global transfer pricing experts work together with you to understand your business and your requirements. This is The Power of Being Understood.• We are the 7th largest global audit, tax and consulting network

• We have firms in over 110 countries • We have combined staff of over 37,500 in over 730 offices across the Americas, Europe, MENA, Africa and Asia Pacific. www.rsm.global.com

Longview makes enterprise software that drives competitive advantages for Finance and Tax teams. Hundreds of thousands of business leaders from Global 2000 companies, operating in more than 150 countries, leverage Longview daily to make strategic and immediate business decisions with confidence. Our software drives speed, accuracy and productivity while delivering critical insights from vast and disparate data points. Longview elevates planning, budgeting, forecasting, tax reporting, analytics and financial close from data collection and validation to strategic business processes. Delivered out of box, advantages are realized quickly. With the recent merger of Longview and Tidemark the art and science of corporate planning came together. Longview’s 25+ years of corporate planning domain knowledge with Tidemark’s state of the art cloud-based platform deliver the most robust and innovative corporate planning solutions in the market place. Longview and Tidemark customers from around the globe unite. They attest to Longview continuing to deliver and now with increased innovation and creativity delivering the platform of the future, powered by experience. Longview’s 25+ years of domain knowledge and experience, combined with our state of the art on-premise and cloud-based platform, deliver the most robust and innovative performance management solution in the market place. Longview is a global company headquartered in Toronto, Canada with offices around the world. www.longview.com

Founded in 1920, Miller & Chevalier is a longstanding Washington, DC law firm with a global perspective and leading practices in tax, litigation, international, employee benefits, white collar defense, and government affairs. Over the past three years, the firm’s lawyers have represented more than 40 percent of the Fortune 100, one-quarter of the Fortune 500, and approximately 30 percent of the Global 100. Miller & Chevalier is a trusted partner to clients in the United States and around the world, providing solutions to their most complex problems, as well as counsel that enables clients to seize new opportunities. www.milchev.com

SILVER PARTNERSAt S&P Global Market Intelligence, we know that not all information is important—some of it is vital. We integrate financial and industry data, research and news into tools that help track performance, generate alpha, identify investment ideas, understand competitive and industry dynamics, perform valuation, and assess credit risk. Investment professionals, government agencies, corporations, and universities globally can gain the intelligence essential to making business and financial decisions with conviction. S&P Global Market Intelligence is a division of S&P Global (NYSE: SPGI), which provides essential intelligence for individuals, companies, and governments to make decisions with confidence. For more information, visit www.spglobal.com/marketintelligence.

Maisto e Associati is an independent Italian tax law firm established in 1991 with offices in Milan, Rome and London. Our transfer pricing team is composed of high skilled persons that come from different professional backgrounds which makes our law firm one of the best recognized in the field. Maisto e Associati provides the full range of transfer pricing services from the development of the transfer pricing policies, drafting of the documentation through to the negotiation and conclusion of Advance Pricing Agreements with the Italian Tax Authorities. The firm has been consistently ranked for several years by independent researchers as tier 1 Italian tax law firm (Chambers & Partners; The Legal 500; International Tax Review, World Tax).

JTP has one simple goal in mind – provide transfer pricing solutions based on “in-the-trenches” experience and a solid reputation of trust within the tax authority community.

JTP specializes in complex TP matters that require an out-of-the-box, business-driven approach. APA’s are at the core of JTP’s practice. We assist MNEs in designing a strategic approach to their APA projects and implementing this strategy throughout the negotiations with U.S. and foreign tax authorities. In addition to APA related services, JTP works with MNEs and their local advisory teams to evaluate global strategic business needs and address TP issues before these issues become TP controversies. https:\\www.JohnsonTP.com


ASSOCIATE PARTNERSBureau van Dijk is now a Moody’s Analytics company. They capture and treat private company information for better decision making and increased efficiency.

Its products combine data from regulatory and other sources, including over 160 information providers, to deliver the richest, most reliable private company information, corporate structures, beneficial ownership and deal information in the market.

With information on around 300 million companies they are the resource for company data. A key benefit of their information is how simple they make it to compare companies internationally.

As experts in company information, they can help you to monitor your global operations and comply with country by country (CbyC) reporting. 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. Welcome to the business of certainty.

As a trusted adviser to small and midsized businesses across the U.S., CBIZ provides our clients with solutions that help them improve their operations and increase profitability. From our many service platforms – in areas ranging from accounting, tax and business advisory services to group health benefits, payroll, property and casualty insurance and retirement plan services – we strive to ensure that our more than 90,000 clients receive the most effective professional solutions. With 4,800 associates in more than 100 offices across the country, CBIZ’s resources and services are uniquely suited to support the growth and success of our clients. www.cbiz.com/accounting-tax/services/tax/international-tax/transfer-pricing

RoyaltyStat® provides economic consulting and expert testimony in transfer pricing and intangible asset valuation. We have expertise in determining arm’s length royalty rates and profit indicators in many industries, including chemicals and lubricants, computers & related devices, luxury consumer goods, machinery, medical devices, pharmaceuticals, software, and telecommunications.

We perform comparable benchmark, determine the “platform” value of separate and distinct intangibles, and prepare transfer pricing reports and purchase price allocation. We build and maintain customized BEPS Action 13 Country-by-Country Reporting (CbCR), Master File and Local File software applications.

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THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS …€¦ · THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS ON THE WEST COAST Inspiration 40+ Speakers 20+ Presentations