Global Transfer Pricing Forum - Europe 2017

Overview

TP Week, the unique and specialist sister publication of International Tax Review, is pleased to host the 17th annual Global Transfer Pricing Forum in London. The event will bring multinational organisations together with leading advisers from law and accounting firms. As publishers with over 25 years’ experience in the TP space, the Forum will lead the debate on the most significant topics and trends in transfer pricing today, with a keynote address from Jefferson VanderWolk, Head of Division Tax Treaty, Transfer Pricing, and Financial Transactions, Centre for Tax Policy and Administration at the OECDMaura Parsons, Deputy Director and Head of Transfer Pricing at HMRC will also be addressing the audience on day two.

The Forum is not intended as a traditional educational style seminar. The aim is to facilitate free and transparent debate on topics from BEPS to dispute resolution. As such, taxpayers are invited to openly share experiences of how to deal with a global transfer pricing environment that is changing rapidly.

Instead of traditional press reporting on the event, TP Week editors will lead the debate with their own probing questions for the expert panellists from industry and practice and will encourage delegates to challenge the speakers' opinions.

Contributions will remain anonymous and confidential but themes that emerge – major concerns, and unanswered questions - will be presented in a report which will be seen by all subscribers to TP Week, including the OECD and major revenue authorities.


REGISTRATION & ENQUIRIES
Alicia Sprott
+44 (0) 207 779 8334
registrations@tpweek.com
Register online here


SPEAKING ENQUIRIES
Sonja Caymaz
+44 (0) 207 779 8264
sonja.caymaz@euromoneyplc.com


SPONSORSHIP ENQUIRIES
Andrew Tappin
+44 (0) 207 779 8661
atappin@euromoneyplc.com

 


Sponsors

 

 

Aptis Global Fenwick & West Grant Thornton Valente Associati GEB Partners

Agenda

Download the brochure here

DAY ONE - 19 SEP

08.30 Registration and breakfast
09.00 Chair’s introduction and opening remarks
09.10 Keynote address:
Jefferson VanderWolk
, Head of Division Tax Treaty, Transfer Pricing, and Financial Transactions, Centre for Tax Policy and Administration, OECD
09.30

Update on BEPS implementation
This panel will focus on the global take-up of BEPS guidelines, from Brazil to India, the US to Japan, and everywhere in between.

Moderator: Filipa Correia, Director – Tax Policy, International Tax Attorney, Valente Associati GEB Partners
Jefferson VanderWolk, Head of Division Tax Treaty, Transfer Pricing, and Financial Transactions, Centre for Tax Policy and Administration, OECD
Camilla Kiss, Tax and Transfer Pricing Manager, Aker Solutions
Miguel Tomé de Medeiros, Transfer Pricing Specialist, Solvay

10.45 Coffee break
11.15

Dispute resolution
In the age of transparency, TP controversy is all but guaranteed. This panel will focus on some of the most significant court cases around the world, lessons learned from them, and strategies to prevent things getting that far.

Moderator: Wendy Nicholls, Head of Transfer Pricing, Grant Thornton
Carolina Graterol, Head of Corporate Tax & Transfer Pricing, Rosen Group
Clive Baxter, Head of Tax Policy and Governance, Maersk
Zahira Quattrocchi, Group Tax Director, Barilla Group

12.30 Lunch
13.40 The work of tax professionals in a dynamic field
Ruth Lynch, PhD Scholar, Kemmy Business School, University of Limerick
Martin Laheen, PhD Scholar, Kemmy Business School, University of Limerick
14.00

Country-by-country-reporting (CbCR) and the new filing requirements
Once a fringe topic, CbCR is now a reality taxpayers have to grapple with. This panel will look at how taxpayers are tackling the new reporting challenges and discuss emerging best practices.

Chris Lenon, Founder, Green Tax
Rocío Bermúdez Becerra, Transfer Pricing Manager, Repsol
Sam Barrett, Head of International Tax & Global Transfer Pricing Director, Sandvik

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.

Moderator: Kathrine Kimball, Managing Principal and Founder, Aptis Global
Sofie Stas, Principal and Founding Member, Aptis Global

17.00 Close of day one
17.15 TP Week 10th birthday party

DAY TWO - 20 SEP

08:30 Registration and breakfast
09.00 Chair’s introduction and opening remarks
09.10

Keynote address:
Maura Parsons, Deputy Director, Head of Transfer Pricing, HMRC

09.30

Transfer pricing in the modern economy
In 2017, tax authorities have been testing the limits for technology companies on hard-to-value intangibles, profit split methods and permanent establishment. This panel will discuss the latest developments and their impact on businesses, including risks related to DEMPE activities.

Moderator: Larissa Neumann, Partner, Tax, Fenwick & West
Julia Ushakova-Stein, Associate, Tax, Fenwick & West

10.45 Coffee break
11.15

Technology and transfer pricing
Blockchain is just one of the many tech innovations that are looking to revolutionise transfer pricing. This panel will take you through some of the most cutting edge technological developments.

Moderator: Andrew Bohnet, Director, Innovate Tax
Mathias Hildebrandt, Group Head of Tax, Zalando

12.30 Lunch
13.30

Survey results from Kemmy Business School, University of Limerick

13.45

European transfer pricing issues
An overview of transfer pricing developments specific to Europe including developments from the European parliament. There will also be discussion on how Europe interacts with the US and with keydeveloping countries

Yordan Nenkov, Group Head of Tax, Coface
Stephanie Li, Tax Director, EMEA, Acer
Andrea Grainger,
Head of Transfer Pricing Advisory, Swiss Re

15.00 Coffee break
15.30

US tax reform
President Trump is looking to embark on a radical overhaul of the US tax system, but details are scarce. What does this mean for transfer pricing? Will his border adjustment tax ever see the light of day? Find out in this panel.

Glyn Fullelove, Group Tax Director, Informa

16.45 Close of day two

Sponsors

 

Aptis Global Fenwick & West Grant Thornton Valente Associati GEB Partners

Speakers

2017 keynote speaker: Jefferson VanderWolk
Jefferson VanderWolk

Head of Division Tax Treaty, Transfer Pricing, and Financial Transactions, Centre for Tax Policy and Administration
OECD

Jefferson VanderWolk is the head of the tax treaty, transfer pricing, and financial transactions division at the OECD Centre for Tax Policy and Administration. He is a lawyer who has been engaged in international tax practice, policy development, and scholarship since 1985. He has been a partner at Baker McKenzie and Deloitte in both London and Hong Kong, a corporate tax director at Merrill Lynch, a special counsel at the IRS Office of Chief Counsel, a law professor in Hong Kong, London, and Washington DC, and international tax counsel to the US Senate Committee on Finance. Before joining the OECD in July 2016, he was with Washington Council EY in Washington DC.

He has published extensively on tax law subjects and participates in numerous professional organisations. He became a fellow of the Chartered Institute of Taxation in 2004, serves on the academic committee for the CIOT’s advanced diploma in international taxation, and is a distinguished fellow of the Chinese University of Hong Kong’s Faculty of Law.  He is admitted to practice in both the US and the UK and is a citizen of both countries.

2017 keynote speaker: Maura Parsons
HMRC

Global Head of Tax and Transfer Pricing 
HMRC

Maura Parsons is the deputy director, head of transfer pricing at HMRC (Business, Assets and International) and chair of HMRC’s transfer pricing and diverted profits boards. Prior to taking on this role in January 2015, she was an assistant director in HMRC’s large business (financial services) where she was a customer relationship manager working with global banks.

This followed a period as head of HMRC’s APA programme, heading up the team responsible for negotiating advance pricing agreements with other tax administrations.

Earlier roles in business international involved acting as policy adviser on the interpretation of UK's transfer pricing legislation and acting as UK delegate to the OECD WP6 Business Restructuring project.


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 from HEC Paris (Ecole des Hautes Etudes Commerciales de Paris). She has more than 20 years of experience in the tax and transfer pricing area. 

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 litigation. In Europe, she has worked as in house tax and transfer price adviser for leading companies in the pharmaceutical, automobile, fast moving consumer goods (FMCG) industry, and the oil and mining sector.

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

Glyn Fullelove

Glyn Fullelove

Group Tax Director
Informa

Glyn Fullelove leads the tax team at Informa. He is also chairman of the Technical Committee and vice president of the Chartered Institute of Taxation. He has worked in tax for over 30 years, and is a Chartered Accountant and Chartered Tax Adviser. He has previously held senior finance roles at a number of UK headquartered multi-national companies, including Williams, Invensys and Misys.

Clive Baxter

Head of Tax Governance and Policy
Maersk

Clive Baxter is head of tax governance and policy at Maersk. With activities that include shipping, offshore industry services, and energy, the group is active in over 120 countries throughout the world. 

Before joining Maersk 17 years ago, Baxter was first vice president of tax at Danske Bank. Baxter is a UK and Danish chartered accountant. He was joint national reporter at the 1996 and 2000 International Fiscal Association congresses and a panellist in 2008, 2014 and 2016. 

During 2009-10, he was president of the EMEA chapter of the Tax Executives Institute and during 2015-2016 was vice president of Region XI (Asia, Latin America and EMEA). He is also a member of the International Chamber of Commerce Tax Commission.

Yordan Nenkov
Yordan Nenkov

Group Head of Tax
Coface

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). Nenkov possesses an exceptional track record in structuring complex cross-border transactions and managing global tax affairs of large multinational businesses.

As group head of tax at Coface, Nenkov 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. Nenkov also manages a team of 11 members including four direct reports and seven indirect reports.

Christopher Lenon
Christopher Lenon

Founder
Green Tax

Chris Lenon is the founder of Green Tax and a consultant on tax transparency, tax policy, transfer pricing and environmental tax. 

Lenon was the global head of tax at Rio Tinto for 17 years from 1993-2010, followed by two years as the company’s group strategic adviser for tax policy from 2010-2012. He chaired the Tax Committee of the Business and Industry Advisory Committee to the OECD until 2012. 

He also chaired the Green Tax Group at Business Europe and was a member of the Tax Policy Group at Business Europe until July 2014. From 1976 to 1986 he worked for HMRC, including 1983-1986 at the Oil Taxation Office. Lenon was a member of the ICC Tax Commission specialising in environmental tax and sustainable development, and a member of the EU Platform for Tax Good Governance.

Mathias Hildebrandt
Mathias Hildebrandt

Group Head of Tax
Zalando

Mathias Hildebrandt heads Zalando’s tax department. Zalando is a fashion and technology company transforming into a multi-service platform for fashion. With a strong workforce of more than 12,000 employees of over 100 different nationalities, the company aims to impact the fashion industry and add value to all players in the fashion ecosystem. In 2016, Zalando had over €19 billion active in 16 European markets and €3.6 billion in revenue.

With more than 12 years’ experience in national and international tax matters Hildebrandt’s mission is to transform Zalando’s tax department into a strong team providing in-house advice.

Hildebrandt can also be seen as a speaker on panel discussions at tax seminars, focusing on transfer pricing, tech and big data transactions, permanent establishments, digitalisation of tax departments as well as tax compliance management.

Prior to Zalando, he worked for British American Tobacco and Baker Tilly Roelfs (now RSM). Hildebrandt is a lawyer and certified tax adviser, holds a Master of business Law and did his Ph.d. at the University of Kiel.           

Rocío Bermúdez Becerra
Rocio Bermudez Becerra

Global Transfer Pricing Manager
Repsol

Since 2013, Rocío Bermúdez Becerra has been the global transfer pricing manager at Repsol, responsible for setting up transfer pricing policies across the group. She is involved in the preparation of worldwide transfer pricing documentation, support in tax audits, providing technical advice to new intercompany transactions, and participation in TP forums (BIAC, Business Europe, UN).

In 2014, Bermúdez Becerra was designated as one of the 15 non-governmental Members of the EU Joint Transfer Pricing Forum (Mandate 2015-2019).

Previously, Bermúdez Becerra worked for Deloitte, both in Madrid and Rotterdam for more than seven years in the transfer pricing and international tax department, dealing with transfer pricing assessment, APAs negotiations and different tax planning projects.

She has a degree in business administration and a degree in law with a masters in corporate taxation. She is also fluent in English and French.

Sam Barrett
Sam Barrett

Head of International Tax & Global Transfer Pricing Director
Sandvik

Sam Barrett is the head of international tax & global transfer pricing at Sandvik, a high-tech and global engineering group headquartered in Stockholm, Sweden. Barrett is responsible for a team of tax lawyers and operational transfer pricing controllers managing the international tax and transfer pricing consequences of the company’s global operations including compliance, planning and controversy. Prior to joining Sandvik, Barrett was global transfer pricing manager for Kimberly Clark where he was in charge of all transfer pricing related activities including TP planning and controversy, as well as global and local country documentation efforts. Prior to joining Kimberly Clark, Barrett gained over 10 years of experience working as an adviser and was responsible for global transfer pricing in a number of multinationals located in the US, UK, Luxembourg and Mexico.

Camilla Kiss
Camilla Kiss

Tax and Transfer Pricing Manager
Aker Solutions

Camilla Kiss is the tax and transfer pricing manager at Aker Solutions, with 10 years’ experience from multinational companies within the automotive and oil & gas industry. She has a broad and varied experience within corporate finance, restructuring, tax and financial due diligence, strategic planning, tax audit, transfer pricing and international taxation. Kiss holds a Masters in finance with an additional executive program in transfer pricing

Kathrine Kimball
Kathrine Kimball

Managing Principal and Founder
Aptis Global

Kathrine Kimball is the managing principal and founder of Aptis Global, headquartered in San Diego, California.

Kimball began her transfer pricing career in 1993 by formulating the analysis for the Yamaha Motors US case. Today, Kimball has nearly 25 years’ experience in global transfer pricing, value chain analysis, intangible property valuation and migration, and supply chain transformation tax planning. Kimball operates in the areas of international tax planning, tax effective supply chain strategy, transfer pricing documentation and defense, having served clients across all major industries. As a truly global transfer pricing advisor, she has served clients around the world: most recently as a global transfer pricing principal with Deloitte, previously as a vice president of CRA, and as a principal with EY, having built practices in Washington, D.C., Brussels, San Francisco, and San Diego.

She is a frequent speaker within international tax circles as well as at corporate and philanthropic events as a motivational speaker in the areas of servant leadership and mentoring. Kimball holds an MBA from the College of William & Mary and a BBA from Loyola Marymount University. She has been named consistently among the "World's Leading Transfer Pricing Advisers" in the Expert Guide published by Euromoney's Legal Media Group as well as in the International Tax Review's "Women in Tax Leaders" guide. She has also been named consistently by in-house counsel and colleagues on Euromoney's short list of "Americas Women in Business Law."

Sofie Stas
Sofie Stas

Principal, Founding Member
Aptis Global

Sofie Stas is a principal and founding member of Aptis Global, serving as the European leader for Aptis, based in Brussels, Belgium.

Stas has 16 years of experience in transfer pricing. She started her career with EY and helped launch the transfer pricing practice within EY Belgium alongside Kathrine Kimball. She participated in global and pan-European transfer pricing and supply chain projects in various sectors such as consumer products, foods and beverages, automotive, biotech, and pharmaceuticals. For more than ten years, Stas worked as an in-house transfer pricing expert for one of the largest banks in Belgium and gained extensive experience in the specific transfer pricing issues related to the financial sector, including financing and global trading. During this time, she also gained experience in addressing the various challenges related to the development and implementation of transfer pricing systems within an international organization. Stas was involved in various transfer pricing audits across Europe and managed the transfer pricing aspects related to business restructuring and post-merger integration.

Larissa Neumann
Larissa Neumann

Partner, Tax
Fenwick & West

Larissa Neumann is a tax partner at Fenwick & West. Her practice focuses on US tax planning and tax controversy with extensive transfer pricing experience. She has successfully represented clients in federal tax controversies at the audit level and in IRS appeals, the US tax court and other federal courts. 

Euromoney’s Women in Business Law named Neumann the “America’s Best Transfer Pricing Lawyer” in 2017. She also was named by Euromoney as one of the “World’s Leading Transfer Pricing Advisors” (2017).

Neumann was counsel in the recent important taxpayer victory involving transfer pricing in tax court for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the 2017 successful resolution for Sanofi Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11-647T. She also is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15, a pending tax court case that also involves § 482.

Neumann appears in International Tax Review's “World's Tax Controversy Leaders” and Euromoney’s “World’s Leading Tax Advisers”.  She also appears in Euromoney’s Women in Business Law (a short list of the top women tax lawyers in the world) and International Tax Review’s “Women in Tax Leaders”. Euromoney Women in Business Law shortlisted Neumann twice for the “America’s Best Lawyer in Tax Dispute Resolution” award. 

Neumann teaches international tax at the University of California, Berkeley Law School and coauthors a monthly column in Tax Notes International.

Julia Ushakova-Stein
Julia Ushakova-Stein

Associate, Tax
Fenwick & West

Julia Ushakova-Stein, an attorney in the Fenwick & West tax group, focuses her practice on US tax planning and tax controversy matters with an emphasis in tax pricing practice and litigation. She has represented a number of Fortune 500 companies in US federal income tax matters and has successfully represented clients in federal tax controversies at all levels.

Ushakova-Stein was on the trial team that won the Analog Devices, Inc. & Subsidiaries v. Commissioner, 147 T.C. No. 15 (Nov. 22, 2016), transfer pricing case and currently is working on TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15, a pending tax court case that also involves § 482. 

Euromoney Legal Media Group “Americas Women in Business Law” named Ushakova-Stein the “Best Rising Star in Tax” in 2017 and she appears in Euromoney Legal Media Group Expert Guides: Rising Stars publication as a “Rising Star in Tax” in 2017.

Recent transfer pricing publications include, “IRS Taking a Hard Look at Transfer Pricing”, Daily Journal, September 2016.

She received her J.D. from the University of California, Berkeley, School of Law and her honors B.S.B.A., summa cum laude, in accounting from the University of Arizona, Eller College of Management. 


Sponsors
Aptis Global Fenwick & West Grant Thornton Valente Associati GEB Partners



Venue

The Waldorf Hilton, London
Aldwych
London
WC2B 4DD

+44 (0) 20 7836 2400

Delegates attending the Global Transfer Pricing Forum can enjoy a preferential discount on accommodation at the Waldorf Hilton. A Queen Hilton Guest Room starts from £259 per night (inclusive of VAT and breakfast). For details on how to reserve your room, email registrations@tpweek.com.

Waldorf Hilton Hotel


Sponsors

 

 

Aptis Global Fenwick & West Grant Thornton Valente Associati GEB Partners

Contact Us

For registration & enquiries, please contact Alicia Sprott on +44 (0) 207 779 8334 or registrations@tpweek.com

For speaking enquiries, please contact Sonja Caymaz on +44 (0) 207 779 8264 or sonja.caymaz@euromoneyplc.com

For sponsorship enquiries, please contact Andrew Tappin on +44 (0) 207 779 8661 or atappin@euromoneyplc.com

 


Sponsors

 

Aptis Global Fenwick & West Grant Thornton Valente Associati GEB Partners