September 18-19, 2013 • Crowne Plaza Times Square, New York

Why attend?

• Find out how the OECD's BEPS project could change your company's approach totransfer pricing

• Apply the latest court decisions on related parties to your business

• Discover how you can use transfer pricing to improve your company's business model

• Learn how governments' transfer pricing priorities will affect you

• Update your knowledge of the opportunities and risks in IP migration

• Gain insights into the latest thinking on dispute resolution and how it can help yourcompany

• Add to your understanding of how transfer pricing can affect your financial transactions

In association with

www.internationaltaxreview.com/TPForum2013

12 CLE/CPE/CPD

points available

Global Transfer Pricing Forum 2013

13th AnnualGlobal Transfer Pricing Forum

September 18-19, 2013Crowne Plaza Times Square, New York

International Tax Review and TPWeek’s 13th Annual Global Transfer Pricing Forum is taking place on September 18 & 19at the Crowne Plaza in Times Square, New York, in association with Deloitte.

Pascal Saint-Amans will give a keynote speech to open the conference, during which the head of the OECD’s centre fortax policy and administration will discuss the Base Erosion and Profit Shifting project, along with developments in the projecton intangible assets.

Other topics up for discussion include supply chain restructuring; lessons from APA programmes around the world; sepa-rate focuses on the financial services, pharmaceuticals and technology, media and telecoms industries; integrating transferpricing with the wider tax department (including indirect tax, IT systems and working with company directors); and transferpricing controversy issues.

The panels will all focus on practical, rather than theoretical, perspectives and will include experienced taxpayers dis-cussing their particular issues and how they overcame them.

The event will also run its ever-popular Ask the Authorities panel, which will allow delegates to pose anonymous technicalquestions to representatives from a number of national revenue authorities and gain an insight into how these countrieswould approach particular issues.

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

Join the Global Transfer Pricing Forum 2013 group on LinkedIn for the latest news about the conference: http://www.linkedin.com/groups?gid=3194275&trk=hb_side_g

Crowne Plaza Times Square Manhattan1605 Broadway At 49th Street New York City, New York 10019United States

Special room rates are available for September 16 & 17,2013 at USD375 + tax per night. To book your room call 1-888-233-9527 from the US and 1-843-760-5839 internationally with the reference Transfer PricingConferenceOr visithttps://resweb.passkey.com/go/TransferPricingConference. Allrooms must be booked before August 23, 2013.

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

Visit: www.internationaltaxreview.com/TPForum2013Call: + 44 (0) 020 7779 8334

Email: mfabri@euromoneyplc.comTwitter: #TPweek

Global Transfer Pricing Forum 2013

International Tax Review

GLOBAL TRANSFER PRICING FORUM 2013September 18-19, 2013 • Crowne Plaza Times Square, New York

8:30 Registration and breakfast

9:00 Opening remarks Ralph Cunningham, Managing Editor, International TaxReviewTodd Wolosoff, Global & US Transfer Pricing ManagingPartner, Deloitte

9:10 Keynote AddressPascal Saint-Amans, Director, Centre for Tax Policy andAdministration, OECD

9:30 An OECD BEPS updateWhat the OECD’s Base Erosion and Profit Shifting project willmean for a company’s tax and transfer pricing arrangements isstill unclear, but one thing most taxpayers will agree on is thatits impact will be significant. This debate will look at:• Recent updates in the project’s development• Economic substance and planning• Permanent establishment issues• What the tax avoidance news headlines really mean

John Henshall, Partner, Co-Global BMO Leader, Deloitte(moderator)John Drewno, Head of Transfer Pricing, CaterpillarInga Kondrataite, Head of Transfer Pricing, AMIE, NissanEuropePascal Saint-Amans, Director, Centre for Tax Policy &Administration, OECD

10:45 Coffee and networking

11:15 Issues relating to intangiblesThe treatment of intangible assets in a company’s transfer pric-ing is still causing headaches and uncertainty for multinationals.This panel discussion will look at practical solutions to issues thatarise from topics such as:• Location savings• Market premiums• Control premiums• Novel intangibles• Assembled workforces

Arin Mitra, Principal, US Intangibles Transfer Pricing Leader,Deloitte (moderator)David Forst, Partner and Chair of Tax Group, Fenwick &WestMelvin Rodriguez, Global Tax Director, WarnacoDavid Cordova, International Tax Partner, DeloitteLynne Sullivan, Vice President of Tax, Biogen

12:30 Lunch

1:40 Keynote AddressBrian Tully, VP & Head, ONESOURCE Transfer Pricing,Thomson Reuters

2:00 APA lessonsApplying for an APA is becoming a relatively straightforwardprocess in developed countries, but developing countries canoffer taxpayers new lessons in negotiation. This panel will cover:• India’s new APA system• Negotiating in China• New programmes in other parts of the world• Case studiesKerwin Chung, Principal, Deloitte (moderator)S.P. Singh, Senior Director, DeloitteEunice Kuo, Tax Partner, DeloitteOscar Molina, Head of Large Business & International Division,Mexican Tax Authority

3:15 Coffee and networking

3:45 Financial services Few industries are more international than financial services.New transfer pricing rules and reforms usually have as significantan impact on such taxpayers as any others. When you includerequirements that are particular to the sector and which alsoaffect transfer pricing, you have a demanding agenda that trans-fer pricing managers in financial services companies have tokeep on top of. Among the topics this panel will cover are: • What capital and liquidity buffers mean for transfer pricing• Transfer pricing risk management for financial services com-

panies• Latest practice on guarantee fees and its effect on intra-

group loan pricing• Documentation requirements in the financial services indus-

tryRobert Plunkett, Principal, Global and US Financial Services TPLeader, Deloitte (moderator)Helio Araujo, LATAM Head of Tax, BNP ParibasBill Yohana, Director, DeloitteJulia Sceats, Global Head of Transfer Pricing, AIGMohammed Iqbal, Global Head of Transfer Pricing, DeutscheBank

5:00 Chairman’s closing remarks

5:15 Cocktail reception

DAY 1 SEPTEMBER 18

All Global Transfer Pricing delegates and speakers are

welcome to join us for drinks, canapés and network-

ing in The Balcony Room.

Sponsors Exhibitors Supported by

International Tax Review

GLOBAL TRANSFER PRICING FORUM 2013September 18-19, 2013 • Crowne Plaza Times Square, New York

8:30 Registration and breakfast

9:00 Opening remarksSophie Ashley, Managing Editor, TPWeek

9:10 Keynote AddressMichael Keen, Deputy Director, Fiscal Affairs Department,International Monetary Fund

9.30 Transfer pricing controversyTransfer pricing can be a particularly litigious area of corporatetaxation. India alone is churning out transfer pricing rulingsalmost daily, some or all of which can impact the way othercountries view certain issues. Taxpayers can hear about:• Hot controversy areas• How to prepare for an audit• Recent decisions and how they should adapt to them

Keith Reams, US Transfer Pricing Controversy Co-Leader,Deloitte (moderator)Don Maher, Director of Tax Planning, The Dow ChemicalCompanyKenneth Clark, Partner, Tax, Fenwick & WestDr. Napoleão Dagnese, Head of International Tax, OerlikonCindy Hustad, Director – Tax Controversy Services, Deloitte

10:45 Coffee and networking

11:15 BRICS and other dynamic economies Transfer pricing regimes are developing quickly around theworld, particularly in growing, or dynamic, economies, as moreand more countries attempt to increase their tax take frommultinational companies. Only a few years ago, rules were basic,or non-existent, in many jurisdictions and ideas such as docu-mentation requirements and audits were not common every-where either. Now the UN TP manual is in place and related-party transactions are coming in for some keen scrutiny under arange of headings, such as financial transactions, managementfees and intangibles. The panellists will discuss topics such as:• The UN Transfer Pricing Manual and how it could help trans-

fer pricing develop around the world• Location specific advantages and location savings: what you

should know about their potential to change in-housetransfer pricing policies

• How you can work with tax authorities in dynamiceconomies to prevent audits becoming disputes

• New APA programmes and their role in achieving certainty

Shanto Ghosh, Leader – Asia Pacific Transfer Pricing, Deloitte(moderator)Sameer Chaudhary, Americas Transfer Pricing Manager,Hewlett-PackardLionel Nobre, Director, Latin America Tax, DellCatherine Damelincourt, Vice President Corporate Tax,AlstomLuiz Felipe Centeno Ferraz, Partner, Mattos Filho

12:30 Lunch

1:40 Keynote AddressDavid Ernick, Spokesperson, USCIB

2:00 Supply chain restructuringWithout constant attention, it can be easy to let your supplychain become too complex and fall into disarray. Companiesstrive to implement simplified models but in reality it can be dif-ficult to know where to start. This discussion will help taxpayers:• Determine best practices• Learn from audit experience in Europe

Andrew Newman, Partner, Co-Global and US BMO Leader,Deloitte (moderator)Matthew Koch, Manager, International Tax & Transfer Pricing,Lexmark International Will Thompson, Director of Transfer Pricing, Brown-FormanJohn Wells, Mid-America Leader, Deloitte

3:15 Coffee and networking

3:45 CanadaCanada’s Conservative government has pursued a determinedlypro-business tax policy. At the same time, it has also paid closeattention to transfer pricing in an attempt to minimise artificialprofit shifting to low-tax jurisdictions. For example, Budget 2013extended the thin-capitalisation rules to trusts and branches ofnon-residents and foreign affiliate rules were reformed to focusmore closely on distributions and reorganisations. It is criticalthat groups with Canadian interests understand how changes toCanada’s transfer pricing regime apply to them. This panel willlook at issues such as: • New foreign affiliate rules and their impact on tax planning• How thin-capitalisation changes affect the debt vs equity

decision• What the BEPS action plan could mean for Canadian tax-

payers• Trends in the Canada Revenue Agency’s transfer pricing

audit and assessment workRob O’Connor, Leader, Canada Transfer Pricing & CompetentAuthority Group, Deloitte (moderator)Claudie Bouchard, Tax Director, Strategy & Planning, Cirque du SoleilKen O’Mahony, Global Head of Tax, Kerry GroupJean-Jacques Lefebvre, Partner, Deloitte

5:00 Chairman’s closing remarks

DAY 2 SEPTEMBER 19

Visit: www.internationaltaxreview.com/TPForum2013Call: + 44 (0) 020 7779 8334 Email: mfabri@euromoneyplc.com Twitter: #TPweek

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Global Transfer Pricing Forum 2013September 18-19, 2013 • Crowne Plaza Times Square, New York

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CANCELLATION POLICY: If you cannot attend you must cancel your registration in writing by 19 August 2013 to receivea refund less a 10% administration charge. Cancellations received after 19 August 2013, or no shows, are liable for the fullconference fee. You may send a substitute to attend in your place at no extra charge, however we must know by 13September 2013 via email. We cannot accept verbal cancellations. If you make your booking online, by email or via thetelephone, you are automatically adhering to our terms and conditions.

REGISTRATION FEE: The registration fee includes participation in the forum on both days, documentation materials, cof-fee breaks, lunches and a cocktail reception at the end of day one. All delegates are responsible for their own accommo-dation and travel.

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

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