Global Transfer Pricing Forum - Europe 2016



TPWeek and International Tax Review were pleased to announce their return to the European transfer pricing conference circuit with the Global Transfer Pricing Forum. Re-launched in Berlin in June 2016, the Global Transfer Pricing Forum addressed global issues from BEPS to technology; IP regimes to dispute resolution; and the digital economy to financial transactions, for an in-house executive audience. 

The Forum was not a traditional educational style seminar. Instead, TPWeek and International Tax Review editors led the debate with their own probing questions for the expert panellists from industry and practice and encouraged delegates to challenge the speakers' opinions and facilitated free and transparent debate on topics such as the meaning of value creation in the BEPS context, the rise in TP disputes and what revenue authorities can do now and in the future.

Delegates asked engaging questions which set the pace for the expert commentators to address audience needs, such as:

  • Do tax executives believe the outcomes in the BEPS Action Plan will lead to more disputes? 89% of delegates believe that it will
  • Which regions carry the most transfer pricing risk? 57% of the audience believed the most risk lies in Asia with LATAM a far second.
  • What changes has BEPS compliance meant for your department? 81% of answers highlighted that there will be extra time spent in this area closely followed by an increase in costs


Transfer Pricing Forum  

"Overall, I enjoyed hearing from speakers and their experiences, their practical approaches and the networking opportunities" 

"Great interaction with the audience from the speakers"

"There was a good mix of industries and company sizes, I made good contacts"

"Enjoyed being able to ask questions and the panel style discussions that took place"

"Interesting questions, great panels and presentations"

Photos from the event will be made available shortly. If you missed out on this year's event, the Forum is also taking place in New York on September 22 & 23.



The Global Transfer Pricing Forum is an annual event taking place twice yearly in Europe and North America. For advance notification of the event's return, register your interest here or email 



Click here to download the brochure

Day one - Wednesday, 29 June

08.30 Registration and breakfast

09.00 Chairman's welcome and opening remarks

Caroline Byrne, Managing Editor, TP Week and International Tax Review

09.10 Keynote address
Christopher Wales,
former UK Treasury and PwC Adviser

09.30 BEPS compliance overview
By the time this panel sits, it will have been almost one year since the final BEPS guidelines were released. Governments will have implemented new legislation and companies’ new tax strategies will be in full flow. This panel will focus on the global take-up of BEPS guidelines, from Brazil to India, the US to Japan, and everywhere in between.

  • Varying tax authority approaches;
  • Pitfalls for taxpayers; and
  • OECD updates on further transfer pricing work

Moderator: Caroline Byrne, Managing Editor, TP Week and International Tax Review
Álvaro de Juan Ledesma,
Tax Policy & Environment, Repsol
Christopher Wales, former UK Treasury and PwC Adviser
Carolina Graterol, Global Head of Tax and Transfer Pricing, Rosen Group
Ralph Cunningham, Asia Publisher, Euromoney Legal Media Group

10.45 Coffee break

11.15 Dispute resolution

Demand for dispute resolution has never been higher for tax and transfer pricing executives. BEPS measures mean that more tax structures and international transactions will be scrutinised and questioned. And, as tax authorities and taxpayers get to grips with the increased compliance burden, more tax controversy is expected.

  • OECD work on dispute resolution;
  • Call for mandatory arbitration; and
  • Governments' ability to process MAP and APA

Moderator: Ralph Cunningham, Asia Publisher, Euromoney Legal Media Group
Carolina Graterol,
Global Head of Tax and Transfer Pricing, Rosen Group
Danny Houben,
Global Head of Transfer Pricing, Shell
Werner Stuffer,
Vice President, Head of Group Tax, ZF Friedrichshafen

12.30 Lunch

13.40 Keynote address

Luis Cariillo, Director - Transfer Pricing, Bureau van Dijk

14.00 Country-by-country-reporting (CbCR)

A fringe tax compliance idea that become a global phenomenon in such a short space of time, CbCR is designed to give tax authorities more information about where multinationals are booking their profits. While most TP professionals are on board with the concept, there is concern about implementation costs and how the information will be used.

  • How to organise your CbCR report;
  • How governments will process the data;
  • Double taxation issues; and
  • Public CbCR

Moderator: Joelle Jefferis, Deputy Editor, TP Week
António Calisto Pato,
Global Head of Tax, Chiquita Brands International
Harm Oortwijn, Director of International Tax, Paramount Pictures
Ross Lyons, Global Head of Tax, Rio Tinto

15.15 Coffee break

15.45 IP regimes

Patent boxes, knowledge boxes and the like are a growing trend, particularly in Europe. However, the concept of implementing an IP regime to attract research and development to a country is not always viewed favourably by policy makers.

  • Various options and the benefits in Europe;
  • The OECD's nexus approach; and
  • Opposition and alternatives

Moderator: Emmanuel Llinares, Global Head of Transfer Pricing, NERA
Tamara Jones Feddoul, EMEA Transfer Pricing Director, Schneider Electric
Philippe Paumier,
Associate Vice President, Global Head of Tax, Sanofi
Ralph Cunningham,
Asia Publisher, Euromoney Legal Media Group
Morten Dyg Rasmussen,
Senior Transfer Pricing Manager, AP Moller Maersk
Philip de Homont, Principal, NERA

17.00 Close of day one and networking drinks reception

Day two - Thursday, 30 June

08.30 Registration and breakfast

09.00 Chair's introduction and opening remarks

Caroline Byrne, Managing Editor, TP Week and International Tax Review

09.10 Keynote address

Jan Loeprick, Public Sector Specialist, Global Tax Team, EFI, The World Bank Group

09.30 The digital economy

The digital economy has expanded exponentially in recent years as businesses develop with technology and the global market place. Action 1 of the BEPS action plan focuses on this issue, but it is also linked to permanent establishment issues, updates to the TP guidelines and controlled foreign company rules.

  • Key features of the digital economy;
  • Pitfalls for governments and taxpayers; and
  • The wider issue of the digital economy in BEPS

Moderator: Caroline Byrne, Managing Editor, TP Week and International Tax Review
Paul Morton,
Head of Group Tax, RELX Group
David Campkin,
Group Tax Director, BBC

10.45 Coffee break

11.15 How to integrate technology with BEPS compliance

With the implementation of BEPS regulations, taxpayers face a need from authorities for reporting more information about their tax operations. Taxpayers need access to real-time information from a strategic perspective.

  • Operational TP – the process of automating your internal transfer pricing process;
  • Data analytics – the process of analysing information on a real-time basis to ensure your TP results are consistent with your TP policies; and
  • CbCR – many taxpayers will seek to automate the information that will be required under CbCR reporting and will want to have the ability to analyse that information in various ways

Moderator: Joelle Jefferis, Deputy Editor, TP Week
Danny Gal,
Head of Transfer Pricing Sales, EMEA, Thomson Reuters
Georg Gam-Jensen,
Global Transfer Pricing Manager, LEGO
Elias Thomas,
Tax & Transfer Pricing, Spotify
Quinten Fourie
, Head of Global Operations, Transfer Pricing, Thomson Reuters

12.30 Lunch

13.30 European transfer pricing issues vs global

An overview of transfer pricing developments specific to Europe, including developments from the European parliament.

  • European developments;
  • How Europe interacts with the US and with key developing countries; and
  • Interesting litigation cases

Moderator: Ralph Cunningham, Asia Publisher, Euromoney Legal Media Group
Brigitte Baumgartner,
International Taxation Manager, Plansee
Palesa Sansole,
Transfer Pricing Specialist, GE Capital
Sam Sim,
President, Tax Executive Institute - Asia Chapter

14.45 Coffee break

15.15 Financial transactions

Globally, regulations for intercompany financial transactions and loans vary greatly. So it is important for in-house tax executives to stay abreast of any amendments to regulations and keep-up with relevant litigation cases.

  • Recent regulation changes;
  • Relevant litigation; and
  • Case studies and experiences of MNEs

Moderator: Joelle Jefferis, Deputy Editor, TP Week
Napoleão Dagnese,
Senior Director, International taxation, Lupin
Yordan Nenkov,
Group head of Tax, Coface

16.30 Close of day two


Chris Wales

Chris Wales  

former UK Treasury and PwC Adviser

Chris Wales is an established policy adviser with an outstanding record of service in government and to governments. He has worked with Prime Ministers and Finance Ministers around the world on economic and fiscal policy, especially revenue policy and administration, and on governance and transparency issues.

At the UK Treasury, Chris led a major programme of tax reform and was closely involved in the negotiation of the EU Savings Directive and the work of the EU Code of Conduct Group on Business Taxation.  He later advised the Prime Minister on broader economic policy issues.
In his role at PwC, he worked with ministers and senior government officials in Central and Eastern Europe, the Gulf States, the Middle East and North Africa and Sub-Saharan Africa. He also worked at ministerial level in the Caribbean. Chris has strong links with the IMF, the EU and the OECD. 

Chris is a member of the Council of the Institute for Fiscal Studies and of the Advisory Board of the Oxford University Centre for Business Taxation, which he was instrumental in founding. He has worked extensively with think tanks and civil society and was a Research Fellow at the Smith Institute. He was a Contributor to the Mirrlees Review on tax policy. He has written articles for the Financial Times and wrote monthly columns for International Tax Review and Economia.

Sam Sim


Tax Executives Institute (Asia Chapter)

Sam Sim is president of the TEI (Asia Chapter) and a former chair of the Capital Markets Tax Committee transfer pricing sub-committee. He leads the EMEA, APAC and Japan transfer pricing function for a Forbes 50 multinational enterprise and was previous deputy head, global transfer pricing of a FT100 financial institution. He had practised as a tax attorney in New York and is also a chartered accountant in his home country.

Paul Morton

Paul Morton  

Group Head of Tax
RELX Group

Paul Morton is Head of Group Tax at RELX Group plc (previously known as Reed Elsevier) where he leads a team supporting businesses in more than ninety countries. The businesses include LexisNexis, a world leading provider of legal, regulatory and news & business information, and Elsevier, publisher of scientific, technical, medical information.

Prior to joining Reed Elsevier Paul held a number of roles at Royal Dutch Shell including head of tax for the global downstream business, European head of Internal Audit, Head of Tax for Shell UK exploration and production and adviser to the global exploration and production business. Before that Paul was a tax manager at KPMG and he originally trained as a tax inspector in the Inland Revenue.

Paul is a member of the CBI and 100 Group Tax Committees and of the Council and Tax Law Review Committee of the Institute for Fiscal Studies. He is a past Chairman of the British Branch of the International Fiscal Association and was a Council member of the Chartered Institute of Taxation and Chairman of its European Branch and Commerce & Industry Group. He is a past President of the Confederation Fiscale Européenne.

Ross Lyons

Ross Lyons  

Global Head of Tax
Rio Tinto

Ross Lyons is Global Head of Tax at Rio Tinto. In that role Ross leads a team of 75 experienced tax professionals based in 9 countries. Ross is a chartered accountant and prior to joining Rio Tinto in Australia in 2007 was a tax partner with Ernst + Young and prior to that Head of Tax at an Australian based chemicals and mining services multinational. Ross has had over 30 years taxation experience as well as experience as a CFO of an Australian regional bank. Ross is Chair of the International Council on Mining and Metals Tax Network.

Rio Tinto operates under a Dual Listed Company structure and has major mining , refining and smelting businesses in Australia, USA, Canada, Indonesia, Africa, Mongolia and France. Rio Tinto is a global leader in tax transparency through its founding membership of the Extractive Industries Transparency Initiative (EITI) and the comprehensive Taxes Paid report, which has been published annually since March 2011.

Carolina Graterol


Global Head of Tax and Transfer Pricing
Rosen Group

Maria Carolina Graterol is a lawyer, specialised in International taxation, with a Master in Business Administration MBA at HEC Paris (Ecole des Hautes Etudes Commerciales de Paris). She has more than 20 years of experience in the tax and transfer pricing area. 

Carolina has advised multinational companies in different industries, first in Latin America where she had her own law firm dedicated exclusively to tax practice specially, international tax litigations. In Europe, she has worked as in house tax and transfer price advisor for leading companies in the pharmaceutical, automobile, fast moving consumer good (FMCG) industry, and oil and mining sector.

She has led multiple business restructuring projects throughout her professional experience in Europe, including conversion of full-fledged distributors into commissionaires, conversion of full-fledged manufacturers into toll manufacturers, centralisation of procurements functions and supply chain reorganisations, and implementation of OECD/BEPS recommendations in multinational companies.

Morten Dyg Rasmussen

Morten Dyg Rasmussen  

Senior Transfer Pricing Manager
A.P. Moeller Maersk

Morten Dyg Rasmussen is a senior transfer pricing manager with the A.P. Moeller Maersk Group based in Copenhagen, Denmark. He has worked extensively with various transfer pricing issues such as valuation of intangible assets, value chain transformation, negotiation of APAs, conflict resolution (MAP), and major transfer pricing audits.

Napoleão Dagnese

Napoleao Dagnese  

Senior Director, International Tax

Dr. Napoleão Dagnese is International Tax Senior Director of Lupin Group (pharmaceuticals) based in Switzerland. He is in charge of international tax matters including transfer pricing planning, implementation and documentation. He has several years working experience in industry and consultancy and was based in Brazil, Germany and Switzerland. He studied law in Brazil, concluded a master in economics, a specialisation in tax law and a Ph.D. in international tax law in Germany, followed by a post-graduation in corporate finance and Swiss taxation in Zurich. He has several publications in leading European and South American journals dealing with international taxation.

Philippe Paumier

Philippe Paumier  

Associate Vice President, Global Head of Transfer Pricing

Philippe is the global head of the transfer pricing team of Sanofi, one of the top healthcare companies present in more than 100 countries with sales of over 33bn EUR specialized in pharmaceutical products, vaccines and animal health. With more than 15 years' experience in the area of transfer pricing and an educational background in Corporate Strategy and Economics, Philippe has been directly involved in major files in a large number of jurisdictions.

His area of expertise includes IP valuation, negotiation with tax administrations, post merger realignment and economic value chain analysis.

Brigitte Baumgartner

Brigitte Baumgartner   International Tax Manager

An accomplished legal professional with a profound knowledge and experience in Taxation and Corporate Law. A highly motivated, hardworking and passionate individual holding an LL.M. Diploma with certificate in Tax Law. A proven background of dealing with complex tax issues and a genuine interest and commitment to matters of taxation.

Palesa Sansole

Palesa Sansole  

Transfer Pricing Specialist
GE Capital

Palesa Sansole is currently working as a transfer pricing specialist for GE Capital International. Sansole has seven years direct transfer pricing experience and overall 16 years tax experience in commerce and 'Big 4' firms.

Sansole has proven project management and management of transfer pricing compliance relating to information technology, including transfer pricing documentation and process improvements. Transfer pricing policy implementation and tax audit defense.

Georg Gam-Jensen

Georg Gam-Jensen  

Global Transfer Pricing Manager
LEGO Group

Georg Gam-Jensen is an internationally focused tax and transfer pricing professional with more than seven years of experience as in-house tax adviser within corporate income tax matters, international corporate income tax matters and transfer pricing.

Georg worked eleven years with the Danish Tax Authorities working as a tax inspector, of which the last seven years were focused on carrying out audits of small and medium-sized corporations in all aspects of corporate income taxation and transfer pricing.

Werner Stuffer

Werner Stuffer  

Global Head of Tax
ZF Friedrichshafen

Werner is the Global Head of Tax for the ZF group. Before joining ZF Werner was an ITS and Transfer Pricing Partner with a big4 in Brazil and Germany and for many years Vice President International Tax for another large German multinational. For four years Werner served as a business expert at the European Joint Transfer Pricing Forum. He has been actively involved in international tax structuring, transfer price planning, audit defense and controversy management including MAP and APAs for many years. In 2007 and 2009 he was elected by the readers of International Tax Review as one of the top 10 tax directors in Europe.

António Calisto Pato

Antonio Calisto Pato  

Global Head of Tax
Chiquita Brands International

António is based in Chiquita's Regional office in Rolle, Switzerland. He has 13+ years of experience in managing international direct and indirect tax, transfer pricing, tax accounting, tax controversy & audit. He has previously worked as an international tax lawyer in different law firms, as a private equity consultant with PwC and as an EMEA Tax Manager for Cemex.

He has been with Chiquita Brands International since 2011 and he is responsible for taxes globally (North America - US, Canada and Mexico, - LATAM, EMEA and APAC). He has experience with Principal/Regional LRD model structures, IP structures, cash pooling and other financing structures, service centers and value chain structuring in general. He has specific experience with planning and compliance for CIT, VAT and Transfer Pricing and with US compliance and reporting. He has also experience in tax controversy having directly managed several audits and court cases from in Europe, US and Latin America.

António has been very much involved in supporting ERP implementation in different countries and in the drafting of an in-house VAT interface to automatise VAT in Chiquita's ERP. He has actively supported - both as advisor and within industry - mergers, acquisitions, spin-offs, take-overs and other type of restructuring.

Tamara Jones

Tamara Jones  

EMEA Transfer Pricing Director
Schneider Electric

Tamara joined Schneider Electric as the EMEA TP Director in 2014 after 9 years in Big Four and mid-sized firms in Paris, London and New York.

She has worked with companies from sectors on areas such as documentation, business restructuring, cost sharing, and controversy.

Tamara has spent the majority of her career working in France defending French companies and  also has significant experience dealing with transfer pricing issues from US and European perspectives.

Ãlvaro de Juan Ledesma

Alvaro de Juan Ledesma  

Tax Policy & Environment

Álvaro de Juan has 20 years of experience in advising on international tax matters, first for a number of years with reputable tax firms and international organisations in Madrid and Amsterdam and subsequently within Repsol group at Madrid.

Initially at Repsol, Álvaro was responsible for tax litigation before Spanish tax Courts and the EUCJ and, later, for Upstream Taxation in different regions (including Europe, Africa, Middle East or Indonesia), supporting local E&P projects; negotiations of contracts and managing tax compliance aspects.

He has recently become responsible for tax policy and environment in the corporate tax department. Over the years,  Álvaro has being a frequent contributor to the OECD, UN and EU tax debates on international taxation. He is also associate professor on international tax at the Universidad Autónoma de Madrid since 2010, and a frequent lecturer at conferences and courses on taxation.

Yordan Nenkov

Yordan Nenkov  

Group Head of Tax

Yordan Nenkov is a multilingual international tax expert with 15+ years of wide-ranging tax experience (including 10 years practicing as a French lawyer in leading law firms in France). Yordan possesses an exceptional track record in structuring complex cross-border transactions and managing global tax affairs of large multinational businesses.

As Global Head of Tax at Coface, Yordan guides the organisation's global tax strategy and proactively manages the tax affairs of the group credit insurance, reinsurance and finance activities in 70+ countries. Yordan also manages a team of 11 members including 4 direct reports and 7 indirect reports.

Danny Houben

Danny Houben  

Global Head of Transfer Pricing
Shell International

Danny Houben is currently Global Transfer Pricing Manager with Shell International BV in The Hague. As the Global Transfer Pricing Manager, he leads a team of transfer pricing advisers involved in the arm’s length operation of their global cost sharing systems and in transfer pricing advice for the upstream and downstream business models. He is also involved in providing strategic direction for the Shell Group of companies regarding audit defence and advance pricing agreements.

Before joining Shell, Mr Houben worked with KPMG, and later with Deloitte, in international transfer pricing in the Netherlands and the United States. Mr Houben is also a lecturer at IBFD and at the LLM curriculum of the University of Leiden for Transfer Pricing Services and Cost Sharing.

Elias Thomas

 Elias Thomas  

Tax & Transfer Pricing

Elias Thomas works as the Transfer Pricing Manager at Spotify, based in the Swedish HQ in Stockholm, where he’s been for the last four and a half years. On a daily basis Elias oversees the entire transfer pricing chain, from analysing the business and industry to implementation and execution.

Being one of the early finance employees at a multinational start-up, Elias has been involved in many of the finance functions managing accounting and tax as well as being highly involved and driving Finance/IT related projects. His combined experience in finance and IT has made the relation between the digital economy and transfer pricing a natural element of the business operations.

Elias holds a Master degree in Business Economics and Administration from Stockholm University and has an academic background in IT Management.

Harm Oortwijn

Harm Oortwijn  

Director of International Tax
Paramount Pictures

Harm J. Oortwijn is Director of International Tax with Paramount Pictures (a Viacom company).

He has 20 years of international tax experience with a number of multinational companies as both in-house professional and tax consultant. He is well-versed in international tax software & solutions development, US & international tax planning and compliance, US GAAP & IFRS tax accounting principles and ERP tax implementation issues.

David Campkin

David Campkin  

Group Tax Director

David is a Chartered Accountant, specialising in Corporate Tax since 1991. He is in charge of the BBC’s global tax affairs, and has been heavily involved in all major transactions and structuring since he joined the BBC in 1997. Although the BBC’s Charter obligations are funded by the licence fee, with a unique tax treatment, commercial activities are undertaken by a £1bn MNG. David is also a Director of several BBC subsidiaries, and a school Governor in Buckinghamshire.

A regular speaker at Tax Conferences, David previously advised clients whilst working at PricewaterhouseCoopers, and KPMG before that.

Luis Carrillo

Luis Carrillo  

Director - Transfer Pricing
Bureau van Dijk

Luis 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
responsible for developing global software solutions for transfer pricing for corporate tax departments and practitioners.

Carrillo holds a BA in Economics from the University of California, Santa Cruz.

Emmanuel Llinares

Emmanuel Llinares  

Head of Global Transfer Pricing
NERA Economic Consulting

Emmanuel Llinares is an economist specialising in inter-company pricing, valuation, and intellectual property analyses. For a number of years, he has advised multinational companies on defining and implementing their intra-group pricing policies and has assisted them with design, documentation, and tax audit defense. Dr. Llinares also assists clients in the context of commercial or intellectual property-related litigations.

Llinares has managed scores of large intercompany pricing projects for multinationals in a wide range of industries, including transportation, energy, chemical, luxury goods, financial services, health care, real estate, media and entertainment, and food and beverage. He has also managed the economic analyses aspects of a large number of tax-related audits in Europe and other regions. He is considered by Euromoney to be one of the world's leading transfer pricing advisors.

Philip de Homont

Philip de Homont  

NERA Economic Consulting

Philip de Homont is part of NERA's Global Transfer Pricing and Intellectual Property Practices, where he provides planning and litigation advice to international corporations and law firms. Mr. de Homont specialises in the defense of complex and unusual transfer pricing and intellectual property cases. 

de Homont has extensive experience in the valuation of financial products and unique intellectual property in a variety of industries, including the pharmaceuticals, telecommunication, consumer goods, banking, and energy industries. He has defended corporate charges, brand and other intellectual property royalties, the valuation of companies or business activities, and complex financial contracts, in particular option-like contracts.

Quinten Fourie

Quinten Fourie  

Head of Global Operations, Transfer Pricing
Thomson Reuters

Quinten Fourie serves as the Head of Global Operations for Thomson Reuters ONESOURCE Transfer Pricing. His main responsibility is overseeing a go-to-market function dedicated to serving transfer pricing professionals in more than thirty countries. Quinten has held a variety of corporate strategy and finance positions within Thomson Reuters and most recently oversaw the global roll-out of a comprehensive BEPS compliance and risk management solution.

Quinten holds a bachelors degree in Economics from North West University in South Africa, trained as a chartered accountant in England and holds a masters degree in business from Duke University in the USA.


Danny Gal

Danny Gal  

Head of Transfer Pricing Sales, EMEA
Thomson Reuters

Danny Gal is Head of the ONESOURCE Transfer Pricing and FATCA/CRS European Sales team at Thomson Reuters. This role includes helping clients on technology enablement, best practice and appropriate controls in relation to Tax & Accounting software. His previous role was Sales Director for Thomson Reuters Risk Management business, where he was responsible for the commercial team and involved in large projects focused on client on-boarding, corporate governance, financial crime. Prior to joining Thomson Reuters, Danny worked at a leading compliance technology company, Complinet and prior to that was working at Microsoft in a Global Account Management role.




Unter den Linden 77
10117 Berlin

Tel: +49 30 2261 0

Delegates are responsible for their own travel and accommodation but there are discounted accommodation rates below:

All rooms available from 28-30 June
Single occupancy: €250 per night

All rates include VAT and service charge as well as access to the gourmet breakfast buffet.

Contact Us

Registration and marketing enquiries
Alicia Sprott
+44 (0) 207 779 8334

Speaking enquiries
Joelle Jefferis
+44 (0) 207 779 8092

Sponsorship enquiries
Megan Poundall

+44 (0) 207 779 8325