Global Transfer Pricing Forum - Washington 2015

Overview

 

2015 celebrated the 15th anniversary of the Global Transfer Pricing Forum, which took place 24 & 25 September at the Park Hyatt Hotel in Washington DC, in association with Deloitte.

Positioned at a critical time with the latest TP developments, many of the OECD's deliverables on the BEPS project are due to be completed by October 2015, making the Global Transfer Pricing Forum one of the last opportunities essential for delegates to gain expert advice and key updates on ensuring their TP strategies are compliant with the new changes.

The BEPS project is also evolving to the point where taxpayers face greater reporting responsibilities to various tax authorities, highlighting the importance for organisations to have access to real-time information from a strategic perspective. Delegates were able to discuss the technological responses to managing operational TP, data analytics and Country-by-Country Reporting (CbCR) to ease the tax reporting burden and provide greater tax transparency.

Panel debates featured speakers from government and in-house tax departments, as well as top transfer pricing advisers where delegates heard how best to cope with compliance burdens and how to combat new audit approaches from government. In addition, this year saw the return of industry-specific break-out panels to allow for a more targeted approach to your delegates' transfer pricing planning.

Delegates in attendance:

  • Gained unrivalled networking opportunities with over 200 international delegates
  • Heard invaluable insights from government, leading tax executives and top transfer pricing professionals and advisers
  • Took away key developments and kept up-to-date with emerging trends in transfer pricing

The event welcomes over 200 tax executives, professionals and private practice every year from the Americas, Europe, Africa and Asia.

For advance notice on the Global Transfer Pricing Forum in 2016, please email registrations@internationaltaxreview.com

 

For speaking enquiries contact Sophie Ashley
Tel: +44 (0) 207 779 8339
Email: sashley@euromoneyplc.com

For sponsorship enquiries contact Megan Poundall
Tel: + 44 (0) 207 779 8325
Email: mpoundall@euromoneyplc.com

For delegate enquiries contact Alicia Sprott
Tel: + 44 (0) 207 779 8334
Email: alicia.sprott@euromoneyplc.com

Agenda

Download the agenda

DAY ONE - 24 September:

09.30 Registration and breakfast

10.00 Chair's introduction and opening remarks

Sophie Ashley, Managing Editor, TPWeek
Todd Wolosoff, Global Managing Partner - Transfer Pricing, Deloitte

10.10 Keynote address

William Morris, Director - Global Tax Policy, GE; Chair, Tax Committee, Business and Industry Advisory Committee to the OECD

10.30 Technology responses to BEPS Transfer Pricing (TP): Operational TP, Data Analytics and Country-by-Country Reporting (CbCR)

As the BEPS process continues to evolve, one thing that is clear is that taxpayers will face a need for more information and greater reporting to various tax authorities. The transparency of information that is coming out of the current BEPS guidance highlights the importance for taxpayers to have access to real-time information from a strategic perspective.  This is leading to various technology solutions in order to meet the various BEPS requirements that are likely to be adopted. This panel will explore these solutions including discussions on:

  • 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
  • CbCR reporting - 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: Boris Nemirov, Partner, Deloitte
Wilson R Vieira Da Silva, Head of Tax, Latin America, Noble Agri
Sam Cicogna, Vice President and Head of ONESOURCE Transfer Pricing, Thomson Reuters
Steve Losavio,  Partner, Deloitte

11.45 Coffee break and networking

12.15 Industry focus and the impact of the digital economy

The digital economy is characterised by a reliance on intangible assets and the problems related to determining the jurisdiction in which value creation occurs.

With a focus on:

  • Transportation & energy;
  • Consumer goods/retail;
  • Media & entertainment
  • Industrial manufacturing

This panel will take delegates through the particular industry-related problems and provide industry insight into how to manage new challenges.

Moderator: Kristine Riisberg, Partner, Deloitte
Gregory Viggiano, Senior Director, Tax Planning & Research, Maersk Group
Fumiko Tamura, Director of Transfer Pricing, News Corporation
George Georgiev, Senior Director, Transfer Pricing and Economic Analyses, Siemens Corporation
Shannon Blankenship, Principal, Deloitte

13.30 Lunch and networking

14.40 Keynote address:

Luis Carrillo, Director – Transfer Pricing, Bureau van Dijk

14.55 A general BEPS update and focus on allocation of risk

In the risk versus planning scenario, how can taxpayers ensure the contracts they have in place for their tax affairs are reliable? The guidance taxpayers receive regarding risk management will have a direct impact on TP planning. The subject of risk allocation is described by the BEPS project as a core aspect of the OECD's work on intangibles. The OECD expects to release guidance in September 2015 and this panel will focus on:

  • Attribution of income to capital
  • The impact allocation of risk will have on future tax planning

Moderator: Tim Tuerff, Partner, Deloitte
Philippe Paumier, Associate Vice President, Global Head of Transfer Pricing, Sanofi
Thiago Figo, Brazilian Tax Executive
Kerwin Chung, Principal, Deloitte
Eric Wang, Partner, Sullivan & Cromwell

16.10 Coffee break and networking

16.45 European focus

This panel will focus on hot TP issues within Europe. The panel will discuss a variety of areas including the impact EC investigations into multinationals deemed to have received state aid from individual states may have on companies in general that operate within the EU. This panel will look at:

  • How companies can avoid making the same mistakes
  • What impact the investigations could make on a company's TP arrangements
  • The EC's focus on patent box regimes

Moderator: Clive Tietjen, Partner, Deloitte
Keith Brockman, EMEA Tax Director, Mars, Inc.
Eduardo Goldszal , Finance Senior Director, NCR Corporation
Ramón López de Haro, Partner, Deloitte

18.00 Close of day one and networking drinks reception


DAY TWO - 25 September:

08.30 Registration and breakfast

09.00 Chair's introduction and opening remarks

Sophie Ashley, Managing Editor, TPWeek 
Todd Wolosoff,
Global Managing Partner - Transfer Pricing, Deloitte

09.10 Keynote address:

Donna McComber,  Deputy Director - Technical, Advance Pricing and Mutual Agreement Program, Internal Revenue Service

09.30 Global disputes

One clear outcome of the BEPS process is a likely increase in global TP controversy. This panel will focus on hot issues in TP controversy around the world, including the most significant court cases in the Americas, Europe and Asia Pac over the past year. The panel will also discuss strategy for controversy management in the post-BEPS era.

Moderator: Keith Reams, Principal, Deloitte
Bradley Shumaker , Tax Counsel, Transfer Pricing, Zimmer Biomet
Marcelo Vicentini , Head of Tax, Standard Chartered Bank Brazil
Kenneth Clark, Partner, Chair, Tax Litigation, Fenwick & West 

10.45 Coffee break and networking

11.15 IP planning

Many companies that are rich in intellectual property operate in countries where corporate tax can take up a significant portion of their profits if they do not plan appropriately. Multinationals are still operating in economically uncertain times. As political issues affect the euro and the price of the dollar fluctuates, it becomes more difficult for companies to establish appropriate transfer prices for IP because of the complexity in first identifying the intangible asset and then determining an accurate valuation. In particular this is increasingly difficult when you consider that not all valuable intangibles are legally protected and registered.

This panel will review the latest BEPS guidance on the issues relating to intangible property and talk about what effective IP planning will look like in the post-BEPS environment.

Moderator: Aydin Hayri, Partner,  Deloitte
Carolina Graterol, Global Head of Tax and Transfer Pricing, Rosen Group
Scott Campbell, Global Transfer Pricing Manager, FMC Technologies
Ted Sutter,
Senior Director, Transfer Pricing, Endo Pharmaceuticals
Philippe Penelle, Principal, Deloitte

12.30 Lunch and networking

13.40 Keynote address

Michael McDonald, Financial Economist, Office of Tax Analysis, US Department of the Treasury

14.00 How to assess historic supply chains in a changing environment

In a rapidly changing global tax environment it is important for taxpayers to manage and moderate their supply chain related planning to ensure that the structures that have been put in place in the past are consistent with the evolving BEPS guidance that will be issued in September 2015. This panel discussion will focus on:

  • What taxpayers should do in assessing prior planning in supply chain restructuring
  • What supply chain restructuring can be expected to look like in the future

Moderator: John Henshall, partner, Deloitte
Pirmin Rohrer, Senior Tax Manager - Switzerland, Dow Europe
Carsten Bonnerup, Global Head of Transfer Pricing, Arla Foods
Todd Izzo, Partner, Deloitte

15.15 Coffee break and networking

15.45 India

With the conclusion of several APAs between India and its major trading partners, India is beginning to make a breakthrough for international investors who have been uncertain about the country's tax environment, in particular, in relation to tax adjustments and disputes in transfer pricing. This panel will look at:

  • Recent important developments for multinational taxpayers in India
  • Strategies that companies should adopt in light of these recent developments

Moderator: Shanto Ghosh, Principal, Deloitte
Nilesh Patel, Head of Transfer Pricing, Taxwize
Douglas W. O'Donnell, Commissioner, Large Business & International Division, Internal Revenue Service
Akhilesh Ranjan, Competent Authority, Indian Revenue Authority
Sanjay Kumar,
Senior Advisor, Deloitte


17.00 Close of conference

Speakers

William H. Morris

William Morris  

Director, Global Tax Policy, GE
Chair, Tax Committee, Business and Industry Advisory Committee to the OECD

Will Morris is currently Director, Global Tax Policy, in General Electric's corporate tax department.

At GE, Will works on a wide range of international tax matters relating to GE's foreign operations, with principal responsibility for coordinating GE's Global (non-US) tax policy program.

After private practice in London and Washington, DC, he joined the IRS in 1995, moving to the Office of Tax Policy at the US Treasury in January 1997 to work on international tax policy. Will was Associate International Tax Counsel until March 2000. At US Treasury his areas of responsibility included subpart F, foreign partnerships and other fiscally-transparent entities, and entity classification issues ("check-the-box").

Will was appointed Chair of the CBI Taxation Committee in London in May 2010, and is also Chair of the AmCham EU Tax Committee in Brussels. He was appointed Chair of the BIAC Tax Committee to the OECD in Paris in November 2012. He is also chair of the European Tax Policy Forum, a registered UK charity that since 2005 has commissioned 40 papers from leading academic economists into business tax issues.



Donna McComber

  Deputy Director - Technical, Advance Pricing and Mutual Agreement Program
Internal Revenue Service 

Donna McComber is Deputy Director of the IRS's Large Business & International division Advance Pricing and Mutual Agreement Program.

She has been with the IRS since April 2007; she is responsible for reviewing US negotiation position for complex transfer pricing transactions and negotiating APA and MAP cases with treaty partners. In addition, she has worked on a number of significant transfer pricing projects including financial products cases and the cost sharing regulation project. In 2009, she earned the Stuart L. Brown National Technical Guidance award.

Prior to joining the IRS, Ms. McComber was a Senior Economist at Baker & McKenzie, involved in advising multinational companies on a broad range of transfer pricing issues. Prior to Baker & McKenzie she was a Senior Manager at Ernst & Young and prior to EY she was an economist in IRS’s Chief Counsel, International APA Program. Ms. McComber has an undergraduate degree in economics from the University of Mary Washington and masters in economics from Vanderbilt University.



Michael McDonald

Michael McDonald  

Financial Economist, Office of Tax Analysis
US Department of the Treasury

Michael McDonald has been a financial economist in the Business and International Tax Division of Treasury's Office of Tax Analysis since 2001.

Michael is a delegate representing the United States at Working Party 6 (Taxation of Multinational Enterprises) of the OECD’s Committee on Fiscal Affairs, as well as a US delegate on a number of WP6 and WP1 (OECD Model Tax Treaty) subsidiary groups. He served as WP6 Co-Chair for the BEPS work on transfer pricing. He is a member of the United Nations subcommittee that drafted the United Nations Practical Manual on Transfer Pricing for Developing Countries, and is a delegate to the OECD's Tax and Development Task Force. He has participated in a number of bilateral income tax treaty negotiations.

As a specialist in transfer pricing, he has worked on a number of significant transfer-pricing projects,
including the final, temporary and proposed cost sharing regulations (2005, 2009, 2011), the services
regulations (2003, 2006, 2009), and the 2007 Report to Congress on Earnings Stripping, Transfer
Pricing and US Income tax Treaties. He has written a number of papers and articles on transfer pricing
and corporate taxation.

Prior to joining the Treasury Department, Michael was a transfer pricing economist in the National Tax Department at Ernst & Young (1996-2001). Prior to working at EY, Michael was on the Revenue Estimating Division at Treasury’s Office of Tax Analysis (1988-1996).

Michael received a Ph.D in economics from Boston College in 1988.



Douglas W. O'Donnell

Douglas W. O'Donnell  

Commissioner, LB&I
Internal Revenue Service

Douglas W. O'Donnell is commissioner of the Internal Revenue Service's Large Business and International (LB&I) Division headquartered in Washington, D.C. In this role, he oversees tax administration activities for domestic and foreign businesses and partnerships that have assets of $10 million or more and a United States tax filing requirement.

Prior to his current executive appointment, Mr. O'Donnell served as the deputy commissioner (International) in LB&I. In this role he was responsible for planning, developing, directing, and implementing a comprehensive service wide tax administration program that enhances compliance with international tax laws, ensures consistency in taxpayer treatment, continuously improves systems and processes and effectively allocates resources to meet service wide international tax administration priorities.

Other executive positions held by Mr. O'Donnell include the assistant deputy commissioner (International); director, Competent Authority & International Coordination; director of International Compliance, Strategy & Policy; deputy director, Pre-Filing and Technical Guidance; and director of Field Operations, Heavy Manufacturing, and Transportation Industry.



Philippe Paumier

Philippe Paumier  

Associate Vice President, Global Head of Transfer Pricing
Sanofi

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 33 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. Sanofi's transfer pricing team, established in several jurisdictions, and comprises 16 individuals.



Carolina Graterol

 

Global Head of Tax and Transfer Pricing
Rosen Group

Maria Carolina Graterol is a lawyer, specialized 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.

Mrs. Graterol 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 leading multiples Business Restructuring projects all along her professional experience in Europe, including, conversion of full-fledged distributors into commissionaires, conversion of full-fledged manufacturers into toll manufacturers, centralization of procurements functions and supply chain reorganizations, and implementation of OECD/BEPS recommendations in multinational companies.



Pirmin Rohrer

 

Senior Tax Manager, Switzerland
Dow Europe

Pirmin Rohrer is senior tax manager at Dow Europe GmbH, Horgen, Switzerland, a subsidiary of The Dow Chemical Company ("DOW") in Midland, Michigan. He joined Dow with the acquision of Rohm and Haas in 2009. Pirmin's experience principally relates to EMEAI tax transactions and tax exposure risks, managing transfer pricing risks and transfer pricing audits, cross-border tax compliance and general tax rate reduction planning with a special focus on Switzerland and Austria. He is a member of the tax group representing DOW in APA negotiations with tax authorities. Most recently, he is the key focal point for BEPS and Swiss Corporate Tax Reform lll related items working on the future tax structure for Dow in Europe.

Prior to his current role, Pirmin worked for 12 years in different positions with increasing responsibility in Finance. Pirmin has a commercial degree and is a Swiss certified specialist for finance and accounting.

 

Thiago Figo

 

Brazilian Tax Executive

Thiago Figo is a Senior Tax Executive and head of tax at the biggest fast fashion retail company in Brazil. He has a Bachelor’s degree in law and post graduation in Tax and is finishing a degree in Accounting.

Previously, he worked for 14 years at PwC, and provided tax services to a variety of industries and sectors such as Embraer, Masterfoods, Motorola, Nexans, Odebrecht, Liebherr, Cummins and Parker Hannifin, amongst others.

During this time, Thiago helped clients to have less of a tax burden and also to evaluate the transfer pricing rules, avoiding undesirable impact on P&L.



Scott Campbell

Scott Campbell  

Global Transfer Pricing Manager
FMC Technologies

A graduate from the University of Arkansas School of Law in 1997, Scott is presently Global Transfer Pricing Manager for FMC Technologies Inc based in Houston, Texas. Scott previously worked for Celanese Corporation, a Fortune 500 MNE chemical company, which he joined in 2005. Scott led the global transfer pricing practice at Celanese (USD $5billion annually in intercompany tangible product transactions) for intercompany transactions relating to tangible products, shared services, IP, royalties, intercompany loans, guarantees and cash pooling.



Eduardo Goldszal

Eduardo Goldszal  

Finance Senior Director
NCR Corporation

Eduardo Goldszal is Finance Senior Director at NCR Corporation, a US-based multinational with over 30,000 employees. Eduardo has a Ph.D. in economics from the New School in New York City. Before joining NCR in 2011 he was a Tax Partner with KPMG. While at KPMG, Eduardo led the transfer pricing practices in the Miami office then Lisbon (Portugal), At NCR, Eduardo is in charge of global transfer pricing. He is involved in different aspects of tax controversy, alternative dispute resolutions, FIN 48 provision, and the day-to-day operational transfer pricing of the Company.



Bradley Shumaker

Bradley Shumaker  

Tax Counsel, Transfer Pricing
Zimmer Biomet

Bradley W. Shumaker currently serves as Tax Counsel, Transfer Pricing for Zimmer Biomet, a medical device manufacturer based in Warsaw, Indiana. He has been involved with working both U.S. and foreign cost sharing and transfer pricing issues from a corporate perspective since 1997. His previous experience includes serving as the global transfer pricing director for eBay, and as the U.S. transfer pricing focal point for Royal Dutch Shell.



Keith Brockman

Keith Brockman  

EMEA Tax Director
Mars, Inc.

Keith was a VP of Tax & Treasury for several US based multinationals, and is currently a member of the Mars Tax Leadership Team, implementing tax strategies and "Best Practices" globally.

He serves on the Tax Practitioner's Advisory Board for KIMEP Law School in Kazakhstan, is a frequent lecturer and author, including the Brockman brief in International Tax Review, and also envisioned and created an International Tax Best Practices blog; strategizingtaxrisks.com.



Marcelo Vicentini

Marcelo Vicentini  

Head of Tax
Standard Chartered Bank (Brazil)

Marcelo Vicentini has more than 15 years of experience in tax advisory and consulting, working in multinational firms, with great knowledge of tax law and double tax treaties within Latin America. He has active participation in the development of new financial products, national and international structured transactions. Currently, he is responsible for the Tax Department at Standard Chartered Bank Brazil and oversees Latin America. He also worked for BNP Paribas, Standard Bank, ING and KPMG.

Mr. Vicentini has a Master Degree in Financial and Economic Law from São Paulo University - USP, Tax Specialization from Universidade Presbiteriana Mackenzie and a Bachelor Degree in Law from Faculdade de Direito de São Bernardo do Campo. He is also professor of Financial and Capital Markets taxation at Insper-Institute of Education and Research.



Carsten Bonnerup

Carsten Bonnerup  

Global Head of Transfer Pricing
Arla Foods

Carsten is the global head of transfer pricing for Arla Foods Group. Arla Foods is a global dairy company. Arla Foods have production facilities in 12 countries and sales offices in a further 30, with a total of more than 18,000 employees.

Carsten's experiences cover transfer pricing strategy, transfer pricing modeling, tax efficient supply chain management, transfer pricing audits, documentations, APAs and other negotiations with the tax authorities.
Furthermore, the transfer pricing operations is of great importance to Carsten, as this area is the basis of running any successful transfer pricing department. Carsten is deeply involved in atomization of operational transfer pricing processes.

During his current and previous assignments Carsten has participated in numerous APA negotiations and MAPs.

Carsten has more than 15 years of experience with tax and transfer pricing, and holds a master of taxation from Copenhagen Business School.



Wilson R Vieira da Silva

Wilson Vieira da Silva  

Head of Tax, Latin America
Noble Agri

Wilson R. Vieira da Silva, currently Head of Tax, Latin America for Noble Agri, has more than 15 years of Brazilian and international tax experience including large law firms, Big 4 accounting firms and in-house experience with both US and non-US multinationals, with a recent focus in the agribusiness and commodity trading space. He has significant experience with international tax planning, transfer pricing, M&A/restructuring, as well as special emphasis on hedging and commodities, in addition to local Brazilian and regional/Latin America tax matters.

Wilson holds a law degree and tax specialization from Universidade Presbiteriana Mackenzie and is a frequent speaker and writer on tax matters.



Gregory Viggiano

Gregory Viggiano  

Senior Director, Tax Planning & Research
Maersk Group


Gregory Viggiano is the Senior Director of Tax Planning and Research for Maersk Group’s US Country Tax Center, where his duties include overseeing US transfer pricing compliance.  Beginning in 2001, Mr. Viggiano created a co-sourced transfer pricing function that leverages internal resources and maximizes value for the Group, including several projects in which transfer pricing was used to achieve important business objectives.

Under Mr. Viggiano’s leadership the US transfer pricing function has successfully supported Maersk Group’s portfolio of businesses in the shipping, marine container terminal, logistics and oil and gas industries, particularly in connection with the evolution of their respective business models.  He also negotiated an Advance Pricing Agreement with the IRS for the Group for the 2006-2010 tax years in conjunction with external counsel. 

Prior to joining Maersk in 2000, Mr. Viggiano had 12 years of experience with both major law firms and Big 4 accounting firms, advising clients spanning the Fortune 500 on all aspects of international, US federal, and state and local taxation. 

Mr. Viggiano presented at the World Trade Institute on the foreign currency exchange aspects of the foreign tax credit and on Section 367, and served as an instructor in KPMG’s internal courses on Basic and Advanced International Taxation.  He has also regularly lectured on transfer pricing at the biennial US Tax Aspects of International Shipping Conference, presented by BNA-CITE (formerly ATLAS), from 2005 to the present. 

Mr. Viggiano received his Juris Doctor degree cum laude from Georgetown University Law Center, and his Bachelor of Arts degree summa cum laude, with majors in both Economics and History, from the University of Richmond.  He is a member of Omicron Delta Epsilon, the international economics honor society, and the New York State Bar. 



Akhilesh Ranjan

Akhilesh Ranjan  

Competent Authority
Indian Revenue Authority

Akhilesh Ranjan is a post-graduate in Physics from St. Stephen's College, Delhi University. He has been in the Indian Revenue Service since 1982 and has worked in various capacities in Pune, Mumbai and Delhi. He has also been a part of the Tax Policy and Legislation division of the Central Board of Direct Taxes during 2000 to 2004, and was instrumental in designing and drafting of the Transfer Pricing regulations introduced in India in 2001. Since July, 2013 he has been posted as Joint Secretary (Foreign Tax & Tax Research) in the CBDT, Department of Revenue, Government of India.  In this post, he functions as the Competent Authority of India under the tax treaties with countries in North America and Europe.  He also represents India in all important multilateral meetings relating to the Base Erosion and Profit Shifting (BEPS) project and the work being done in the area of automatic exchange of information.



Fumiko Tamura

Fumiko Tamura  

Director of Transfer Pricing
News Corporation


Fumiko Tamura is the Director of Transfer Pricing at News Corporation. In her role, she is responsible for overseeing global transfer pricing of the media company with revenues of over $8 billion. Prior to joining News
Corporation in 2013, Fumiko was a Senior Manager in Deloitte's transfer pricing practice in New York.

Fumiko holds a Ph.D. in economics from Brown University and is a licensed Certified Public Accountant in the State of New York.



George Georgiev

George Georgiev  

Senior Director, Transfer Pricing and Economic Analyses
Siemens Corporation


A Senior Director in charge of transfer pricing with Siemens Corporation, USA, Dr. Georgiev has eighteen years of experience in the field. Before joining Siemens, he spent 10 years as a consultant with Big 4 companies in the United States and Europe assisting multinationals from 25+ industries with transfer pricing planning, documentation, APAs and audit defense. The projects that Dr. Georgiev has managed include transfer of tangible and intangible products, cost-sharing, financing and services rendered for the benefit of related parties.

As Head of Transfer Pricing with Siemens Corporation, he has focused on IP issues and economic support to multiple APAs and MAPs. Dr. Georgiev provides transfer pricing training to Siemens employees globally. He has a Master’s Degree in International Business, Master’s Degree in Business Economics and a Ph.D. in Economics.



Ted Sutter

 

Senior Director, Transfer Pricing
Endo Pharmaceuticals



Todd Wolosoff

Todd Wolosoff   Global Managing Partner - Transfer Pricing
Deloitte

Todd Wolosoff is the US and global managing tax partner for Deloitte's transfer pricing practice. He has been a tax partner in the New York City office of Deloitte for the last 25 years. He has extensive experience representing multinational companies in a wide variety of transfer pricing matters.

Wolosoff was the founding partner of the northeast transfer pricing group in 1990. He was a founding member of the national transfer pricing leadership group and has been in a leadership role for Deloitte in the transfer pricing area for more than 20 years.

Wolosoff has provided transfer pricing advice to many of the world's largest multinationals. He has conducted transfer pricing planning and documentation studies for both inbound and outbound taxpayers in virtually all industries, with a particular focus on: consumer products; life science and pharmaceuticals; electronics; automobile and automotive parts; medical products; chemicals; cosmetics; trading companies; and financial services.

Wolosoff is one of Deloitte's leading specialists in transfer pricing controversy, directing audit teams that have negotiated successful settlements in more than 50 audit controversies. He has been involved in a number of ground-breaking audit cases and has led many of the largest transfer pricing audit engagements conducted by the firm in the US. He has also participated in transfer pricing audits in Canada, France, Italy, United Kingdom, and Japan. For the past decade, Wolosoff has led Deloitte's highly attended annual webcast on strategic planning for transfer pricing controversy.

Wolosoff has been recognised every year by Euromoney as one of the world's leading transfer pricing advisors since the guide's inception in 1999. International Tax Review awarded Deloitte the North America Transfer Pricing Firm of the Year, as well as New York Transfer Pricing Firms of the Year 2011-2012.



Shanto Ghosh

Shanto Ghosh   Principal
Deloitte

Shanto Ghosh is a principal in Deloitte's Transfer Pricing practice in the US and is based in Boston. He has over 15 years of transfer pricing experience and leads Deloitte's transfer pricing team in the Greater Boston area.

Ghosh has significant experience in advising clients from the life sciences, technology (including media and telecom), and automobile sectors. He has been actively involved in assisting clients with their global transfer pricing policy and documentation, and has implemented a number of large-scale global supply chain restructuring projects. He has significant experience in assisting clients on transfer pricing litigation and dispute resolution strategies and has been recognised in Euromoney Legal Media Group's World's Leading Transfer Pricing Advisers four times in a row.

He has also been a visiting lecturer at the IBFD Netherlands and is a member of International Taxation magazine's editorial board. He is a frequent speaker at international conferences across the globe and has published a number of high-profile articles. He has advised the Government of India on transfer pricing policy matters and has also been involved with the OECD and the WCO in joint discussions related to the interplay between customs and transfer pricing valuation.



Todd Izzo

Todd Izzo   Partner
Deloitte 

Located in Pittsburgh, Todd spends a significant amount of time servicing large multinational corporations worldwide in a variety of industries, including manufacturing and consumer business.  Todd specializes in international taxation, with a focus on global tax optimization, financial products and instruments, international mergers, acquisitions, reorganizations, tax treaties, foreign tax credit planning and other areas of U.S. corporate and international taxation. 

Prior to joining Deloitte & Touche in 2000, Todd worked in the area of international and corporate tax for five years in the Washington, D.C. office of Dewey Ballantine and served as a law clerk for one year in the chambers of Judge Ed Becker of the U.S. Third Circuit Court of Appeals. 

Todd received a B.S. degree with highest distinction in Accounting from Penn State University, a J.D. degree summa cum laude from the University of Pennsylvania Law School and an LL.M. in taxation with highest distinction from Georgetown University Law Center.   Todd was awarded the May 1991 Alexander E. Loeb Gold Medal award for the high score in Pennsylvania on the CPA exam and the Elijah Watt Sells Award for one of the top scores in the U.S. 

Todd is a frequent speaker on international tax matters and has served as an adjunct professor at both Duquesne and Robert Morris Universities.



Keith Reams

Keith Reams   Principal
Deloitte

Keith Reams is the US and global leader for clients and markets for Deloitte's global transfer pricing services practice. He has advised clients around the globe on intercompany pricing transactions with respect to income tax regulations in the US, Europe, UK. South America, and South East Asia. He has assisted numerous multinational companies with international valuation and economic consulting services involving merger and acquisition activity, international tax planning, and restructuring and reorganisation of international operations.

Reams is on the global tax management team for Deloitte's technology, media, and telecommunications practice and is a leader in the area of transfer pricing for newly emerging industries, such as electronic commerce and cloud computing, where he has extensive experience around the world in helping clients extend their business models into new territories.

Reams has testified as a qualified expert in numerous valuation and transfer pricing disputes, including the cases of: Nestle Holdings Inc v Commissioner ; DHL Corp v Commissioner; and United Parcel Service of America, Inc v Commissioner . In addition, he is one of only three economists in the United States approved by the New York State Department of Taxation and Finance to provide transfer pricing expertise and testimony in cases involving cross-border transactions within commonly controlled affiliated groups. He has also helped many clients to successfully resolve valuation and transfer pricing disputes before they reach trial.



Boris Nemirov

Boris Nemirov   Partner
Deloitte

Boris Nemirov's experience includes over 15 years of transfer pricing economic consulting. Nemirov has significant experience in dealing with transfer pricing issues impacting multinationals, covering tangible, service, intangible and financial transactions. In recent years, he worked on several planning engagements aimed at optimising and streamlining, from a tax and transfer pricing perspectives, business changes and cost-cutting initiatives of several multinational giants. Nemirov has also led engagements for multinational companies with the objective of optimising the intellectual property ownership structure for better alignment with business objectives and natural organic growth of the organisations.

Nemirov is the US Transfer Pricing Technology Leader and spearheads the Operational Transfer Pricing and Data Analytics initiatives partnering with the Tax Management Consulting Group to deliver these cutting edge solutions to clients. Over the past six years, he was heavily involved as a subject matter expert in, and now globally leads, a project to design the next generation transfer pricing modeling and reporting software that has already been successfully used by the group worldwide for the past three years. He is also responsible for managing all software and databases utilised by the US transfer pricing practice.

Nemirov is a Deloitte Faculty Excellence certified facilitator and also actively participates in numerous national initiatives, including those aimed at Deloitte's response to BEPS and was nominated to appear in the 2013 Guide to the World's Leading Transfer Pricing Advisers, which was released in September 2014.



Steve Losavio

Steve Losavio   Partner
Deloitte

 

 

Aydin Hayri

Aydin Hayri   Partner
Deloitte

Aydin serves as the life sciences industry leader for Deloitte's transfer pricing practice, and also manages Deloitte's Greater Washington and Philadelphia transfer pricing practice groups. He has been with Deloitte since 1998.

Aydin assists clients with transfer pricing planning involving intellectual property development, cost sharing, and licensing strategies; and planning and implementation of supply chain and business model restructurings. In addition to life sciences industry, his transfer pricing and tax planning experience covers defense/aerospace, and high-technology manufacturing, and software industries.



Philippe Penelle

Philippe Penelle   Principal
Deloitte

Philippe is a Principal with the Washington National Tax office of Deloitte Tax LLP, specializing in designing, valuing, and defending transactions that involve the transfer of intellectual property rights. Philippe brings over 17 years of professional transfer pricing experience assisting his multinational clients set-up, maintain, document and defend transfers of intellectual property rights through cost sharing arrangements, contributions to international partnerships under 26 U.S. Code §704, contributions to corporations under 26 U.S. Code §367, and licensing arrangements involving specific allocations of fixed cost funding commitments.

In addition to his extensive client work in the Life Sciences, Technology, Video Game, Entertainment and Media, Fashion, and Retail industries, Philippe has published a number of articles developing valuation methodologies relevant to various intellectual property structures consistent with the OECD Transfer Pricing Guidelines, the Internal Revenue Code and the Treasury regulations promulgated thereunder. These articles have been published in Bloomberg BNA Transfer Pricing Report, International Tax Review, Global Tax Weekly, and Bloomberg BNA Tax Management Memorandum.

Philippe currently serves as the Co-Chair of the United States Council for International Business (USCIB) Transfer Pricing Subcommittee. He is actively involved in the Base Erosion and Profit Shifting (BEPS) conversations with the OECD, the U.S. Treasury Department, and with the international business community. His involvement has included the drafting of comments submitted on behalf of Deloitte Tax LLP to the OECD, providing input to the USCIB's and to the Business and Industry Advisory Committee to the OECD’s (BIAC), as well as being an invited speaker at the OECD public consultations in Paris, France.

In addition, Philippe is currently recognized by Euromoney Legal Media Group as one of the world's leading transfer pricing advisers.



Kristine Riisberg

Kristine Riisberg   Partner
Deloitte

Kristine Riisberg is a principal in Deloitte's New York office. She has more than 16 years of transfer pricing and international tax experience with Deloitte and spent four years in Deloitte's Washington national tax office.

Riisberg has extensive experience in company financial and quantitative research analysis and industry data analysis in a wide range of industries. She has prepared economic analyses, documentation, planning, competent authority requests and cost sharing studies for clients across a range of industries including media and entertainment, telecommunications, high-end luxury goods and financial services.

Riisberg has an international background and experience working in Deloitte transfer pricing teams in Copenhagen and London building up an extensive knowledge of global transfer pricing matters. She is the global and US transfer pricing all-industries programme leader, and the Americas transfer pricing leader of the technology, media & telecommunication industry programme. She assumes the global lead tax partner role for the world's largest container shipping conglomerate, the global lead TP role for one of the world's largest media conglomerates and the global lead TP role for the largest European-headquartered consumer and industrial goods conglomerate.

Prior to joining Deloitte, Riisberg was an international tax manager at Andersen's Copenhagen office. Before joining Andersen, she worked at the European Commission in Brussels in the Cabinet of the Danish Commissioner for Energy and Nuclear Safety.



Shannon Blankenship

Shannon Blankenship   Principal
Deloitte

Shannon Blankenship helps companies wade through complexities to find practical solutions for setting up, changing, or defending their intercompany pricing arrangements. This includes creating a consistent global narrative for global documentation, performing headquarter cost allocation studies, evaluating BEPS readiness, considering the value of intangibles, requesting APAs, and conducting planning studies to prepare for the future.

As the Retail and Consumer Products leader for Deloitte Tax's transfer pricing practice, Blankenship helps companies in this industry stay in front of key issues like brand ownership, impacts of digital economy, and local region intangible generation. Two key focuses of Blankenship's practice includes Real Estate Investment Trusts (REITs) and large transfer pricing planning projects involving business reorganizations and intangible property valuations.



Tim Tuerff

Timothy Tuerff   Partner
Deloitte

Timothy Tuerff is the managing partner of the Washington National Tax Office of Deloitte Tax. In this role, he leads the Washington national tax practice in providing tax analysis to clients engaged in multinational corporate and investment transactions. The professionals of this office analyse issues and transactions with respect to specific client matters as well as review current tax developments and their impact on Deloitte clients. Tuerff also serves as a member of the board of directors of Deloitte.

Tuerff specialises in international tax issues and serves US-based multinational corporate clients engaged in cross-border transactions. His practice involves tax analysis related to structuring international business operations, mergers and acquisitions, financing, and utilisation of foreign tax credits. He testified before the US Congress Ways and Means Subcommittee on Select Revenue Measures concerning Chairman Camp's 2011 International Tax Reform Discussion Draft addressing a territorial system of taxation.

Tuerff formerly served as special assistant to the chief counsel and special assistant to the associate chief counsel (international) of the Internal Revenue Service. He is a frequent contributor to tax periodicals, including: Tax Notes and Tax Notes International and the Practicing Law Institute journal Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances; the American Bar Association, International Franchising Journal; and the BNA Tax Management Portfolio, Outbound Tax Planning for US Multinational Corporations, No.6380. Tuerff is also a frequent speaker at seminars on international tax issues addressing such groups as Tax Executives Institute, International Fiscal Association, and the Tax Council Policy Institute Symposium. He currently serves on the advisory board for the Internal Revenue Service – George Washington University International Tax Symposium



Kerwin Chung

Kerwin Chung   Principal
Deloitte

Kerwin Chung is the Managing Principal of Deloitte's Washington National Tax Transfer Pricing Team and Leader of Deloitte's U.S. Advance Pricing Agreement and Mutual Agreement Procedure Team. Chung graduated from Harvard law School and has more than 20 years of transfer pricing experience. Chung has been been selected as one of the "World's Leading Transfer Pricing Advisors" by Euromoney Magazine for every edition since 2002.

Chung's practice includes representing clients before the IRS and foreign tax authorities regarding transfer pricing and OECD BEPS tax matters, including negotiating Advance Pricing Agreements (APAs) and Mutual Agreement Procedure (MAP) cases.



John Henshall

John Henshall   Partner
Deloitte

John Hensall is global co-lead for Deloitte's Business Model Optimisation (BMO) services, specialising in Intellectual Property transactions. Initially training with HMRC, he joined in 2001 and represents Deloitte UK to HMRC on transfer pricing technical matters and Deloitte globally at OECD, including on their Base Erosion and Profit Shifting initiative.

Henshall is the author of Global Transfer Pricing: Principles and Practice (2nd ed) and a contributing author on transfer pricing to Ray: Partnership Taxation.



Clive Tietjen

Clive Tietjen   Partner
Deloitte

Clive is a partner based in the Reading office in the firm's Global Transfer Pricing Group and leads the UK transfer pricing practice for the UK offices outside London.

Clive helps clients with all aspects of designing, implementing and operating transfer pricing policies and supporting those policies under audit. He leads the European and Global transfer pricing arrangements for a number of foreign owned and UK based multinational
groups. He has significant experience in helping businesses manage their transfer pricing risk through the structuring of arrangements which are practical and consistent with their business model, and addressing the transfer pricing and associated tax issues caused by
business change (including permanent establishment and exit considerations).

He also spends a lot of time partnering with clients to prepare robust bespoke documentation, helping them develop on-going compliance processes to monitor results and business changes as well as managing tax audits. In particular, more recently, he has been helping those clients adapt to the greater obligations being imposed by increasing local requirements, likely greater tax authority scrutiny and the proposals for more prescriptive central documentation contained in the OECD's Base Erosion and Profit Shifting Action 13. He is part of Deloitte's global group looking at developing processes and tools to help businesses manage these obligations.



Ramón López de Haro

Ramon Lopez de Haro   Partner
Deloitte

Ramón López de Haro is a cross-border tax and transfer pricing partner with the Deloitte Spanish practice with over 18 years of experience working with large multinational companies. He was recruited as a consultant in the international tax division of Andersen Spain in 1996 (afterwards called Garrigues) where he has developed his career until October 2012. As a leader of the Business Model Optimization (BMO) practice in Deloitte Spain, he now advises both Spanish and foreign multinational companies on cross border tax, transfer pricing, supply chain management and business restructuring processes.

In the last few years Ramón has participated in numerous important supply chain and transfer pricing projects, including:

  • The definition and deployment of shared service centers, cost sharing agreements and general transfer pricing policies for numerous MNCs
  • Design and implementation of procurement companies, intragroup financing centers and IP companies
  • Definition and operation from a tax and transfer pricing standpoint of principal structures for manufacturing, distribution and service activities.
He has also been involved in some of the most important Advance Pricing Procedures (APAs) which have been negotiated in Spain, both bilateral and multilateral, as well as on advising companies in the framework of Mutual Agreement Procedures (MAPs). Ramon has great expertise in all kinds of appeals and claims, and in acting in judicial review proceedings on transfer pricing cases.



Sanjay Kumar

Sanjay Kumar   Senior Advisor
Deloitte 

Sanjay Kumar is Senior Advisor in transfer pricing group of Deloitte India, covering Advance Pricing Agreement (APA) & Mutual Agreement Procedure (MAP) projects. He is also involved in policy initiatives in tax in Deloitte India.

Sanjay Kumar has more than 28 years of experience with the Indian Revenue Service. In government, he worked as regional Commissioner for International Taxation and Transfer Pricing, and was member of five dispute resolution panels at various places in the country. Sanjay’s last assignment in the government was Secretary of the Tax Administration Reform Commission. Sanjay has also worked in the Central Board of Direct Taxes as Commissioner, and was on the Government of India’s expert committees on black money estimation and revenue forecasting.

Sanjay has also been an adjunct faculty at the prestigious Duke University since 2004. Sanjay has a number of publications in reputed national and international journals on topics of transfer pricing, international taxation, international trade, tax policy, and tax administration.



Kenneth Clark

Kenneth Clark   Partner, Chair, Tax Litigation
Fenwick & West

Kenneth Clark is a partner in the Tax Group of Fenwick & West LLP and chairs its Tax Litigation Practice. Fenwick has received numerous accolades for its tax controversy practice, including recognition by International Tax Review as U.S. tax litigation firm of the year in three different years. The principal focus of Ken's practice is complex federal tax litigation and tax controversy work. He regularly practices in the United States Tax Court and has published a number of articles relating to tax controversies.

Ken has worked on numerous high profile tax controversy matters, for clients such as Xilinx, Inc.; The Limited, Inc.; Limited Brands, Inc.; Textron Inc.; Daimler AG; G.M. Trading; Dover Corporation; Adaptec, Inc.; Analog Devices; and CBS.

With over three decades of experience, Ken also has managed a variety of complex commercial disputes in a number of foreign countries and more than twenty states. Litigation prevention and alternative dispute resolution (ADR) also have been important parts of his practice. He has served as Fenwick & West's ADR coordinator, as an American Arbitration Association arbitrator, and has been involved in numerous mediations and arbitrations.



Nilesh Patel

Nilesh Patel  

Head, Transfer Pricing
TAXWIZE

Nilesh Patel heads the Transfer Pricing practice of TAXWIZE, a Professional Firm of India, consisting of Ex-Big 4 Tax and Transfer Pricing professionals.
He is Author of a Comprehensive Book on Transfer Pricing (India). He has also published several Articles in the Journal "Corporate Professionals Today".

He has worked as Additional Commissioner of Income Tax in the Indian Revenue Service and as Senior Manager at Deloitte.

Nilesh advises MNCs on various aspects of Transfer Pricing: planning, policy, benchmarking, documentation, APAs, and dispute resolution. For MNC clients he has done planning for re-allocation of FAR by way of Business Restructuring.

Nilesh also argues cases before the Indian Tax Authorities and Tax Tribunal; and has successfully defended Transfer Pricing policies of his Corporate clients.



Sam Cicogna

Sam Cicogna  

Vice President & Head of ONESOURCE Transfer Pricing
Thomson Reuters

Sam Cicogna brings a unique perspective to his job as VP & Head of ONESOURCE Transfer Pricing for the Corporate Division of Tax & Accounting. Even prior to becoming an employee he touched the Thomson Reuters product suite in various ways, as a client, steering committee member, competitor, and public accounting firm user. These prior experiences allow Sam to directly understand both the market needs and the challenges of who use our products and services on a daily basis.

Sam has worked for Thomson Reuters since 2008, when his employer at the time, TaxStream, LLC was acquired to solidify the ONESOURCE product offering suite. Since the acquisition he has been challenged with merging diverse services teams, creating a single culture and using his experience to expand his teams' mindsets and offerings.

Sam holds a Bachelor of Science in Business Administration (Accounting) from the University of Dayton and is a licensed Certified Public Accountant in the State of Georgia. He is a member of the AICPA & the Association for Computers & Taxation.



Eric Wang

Eric Wang  

Partner
Sullivan & Cromwell

Eric Wang is a member of Sullivan & Cromwell's Tax Group and concentrates on U.S. tax matters. A partner since 2010, Mr. Wang advises on a broad range of planning and transactional matters for both U.S. and non-U.S. clients. He has advised extensively on cross-border acquisitions and joint ventures, including structuring a number of investments made by private equity and real estate funds worldwide. He also advises on U.S. tax issues relating to tax-sensitive financing structures and novel financial instruments, as well as debt restructurings. In addition, Mr. Wang has represented clients with respect to IRS audits and investigations. Mr. Wang has also advised clients on their response to and compliance with the Foreign Account Tax Compliance Act (FATCA) since its introduction in late 2009.

Clients he has advised recently include AB In-Bev, Barclays, Diageo, Goldman Sachs, Rhone Capital and Total.



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.

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

 

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