2024 Agenda (Technical Workshops Day)
2024 Agenda (Technical Workshops Day)
This Transfer Primer Primer session is the perfect start to your TP Minds Americas 2024 learning journey. Developed to provide a solid introduction to Transfer Pricing for those transitioning into a TP-focused role from a general tax background, the session is also an ideal refresher o key principles for those already working in transfer pricing. TP professionals at all seniority levels are therefore welcome. Our two-hour workshop, expertly led by Paul Burns, is structured as follows:
- Part I: TP overview/ refresher
- What is transfer pricing?
- Regulatory framework
- Implementation, processes, and technology
- Part II: Unlocking value in TP
- Integration & harmonization
- Controversy strategies
- Paul Burns - Transfer Pricing Managing Director, BDO
- Neha Shah - Director- Global head of Tax/TP, Product Strategy, MOODY'S
The global trade environment continues to face disruptions caused by inflation, high interest rates, geopolitical tensions and a rapid increase in governmental regulations. In addition, global companies continue to focus on minimizing risks by examining options to reconfigure their value chains and production networks. This session will discuss tax model impacts related to the current trends in global operating model re-globalization/regionalization.
- Larry LeBlanc - Partner, International Tax Services, RSM
- Mounika Maddipatla - Transfer Pricing Manager, RSM
- Matt Dollard - Principal, Management Consulting, RSM
This workshop session will cover the following aspects of APAs and MAPs:
- Transfer Pricing Risks –
- Common transfer pricing risks
- Factors that can heighten these risks
- Adjustments
- Resulting Obligations
- Ways taxpayers can manage that risk
- APAs
- MAPs
- APA v. Non APA Approaches
- Other
- Considerations when determining appropriate risk mitigation approach
- APAs
- Utility Analysis
- Benefits of APAs
- Detriments of APAs
- When to choose APA route
- Case Selectivity
- How the IRS chooses which cases are appropriate for APA program
- How to increase likelihood of being chosen
- Alternative options (i.e. ICAP)
- Utility Analysis
- MAPs
- Double Taxation
- Accelerated Competent Authority Procedure
- Caselaw update (IRS Wins/Losses)
- Enforcement Trends
- IRS Priorities
- Best/Worst Practices
- Statistics
- From APMA program
- From OECD
- APAs
- Kirsten Burmester - Member, CAPLIN & DRYSDALE
- Arjun Ghosh - Associate, CAPLIN & DRYSDALE
Amount B of Pillar One has received relatively little attention, while the merits of Amount A and the intricacies of Pillar Two have been debated over the last two years. Nonetheless, Amount B has moved forward with expected implementation in the OECD Transfer Pricing Guidelines in early 2024. The aim of Amount B is to “streamline the process for pricing baseline marketing and distribution activities in accordance with the arm’s length principle.” While key implementation provisions of Amount B are yet to be finalized, this workshop will provide an overview of the key concepts of Amount B, discuss and debate the pros and cons of the unresolved issues, and consider the potential impact for both marketing and distribution operations and for other intercompany transactions not intended to be covered by Amount B.
- Laurie Dicker - National Tax Office, Technical Tax Practice Leader - Transfer Pricing, BDO
- Margaretha Haeussler - Executive Director, Transfer Pricing, NOVARTIS