June 2022|HILTON BANKSIDE HOTEL, London
The world's largest gathering of Transfer Pricing Minds is back!
Featuring in-house TP leaders, top specialist advisers and the leading policy makers reshaping the International Tax landscape
2021 Speakers Included
TP Minds International 2021 Offered Full Coverage of These & Many Other Essential Topics
Pillar 1 Impact on Transfer Pricing
This industry panel addressed the impact for corporations of the continued efforts by the OECD to address the tax challenges of digitalisation through the Unified Approach as set out in its Programme of Work. Areas under examination included: the allocation of taxing rights between jurisdictions and nexus; permanent establishment notions and the applicability of the arm’s length principle. Panellists considered the impact of these proposals on TP operations and map-out what the future of corporate transfer pricing under Pillar 1 might entail.
Pillar 2 & Global Minimum Taxation
Industry panellists discussed the impact of Pillar 2, and the development of new global minimum tax rules, and considered whether this will be an effective means to prevent tax competition between countries and a race to the bottom so far as the collection of tax revenues by fiscs is concerned. What does this mean for the future of transfer pricing? What are the implications for intragroup trading? What will the U.S. position be? These and many other questions were explored by our panel.
Evolving Business Models
This session covered examples of business model transformation. Technology is redefining how companies do business and what businesses they are in. Customers are defining the strategies and delivery models of those companies serving and supplying them. New supply chains are emerging in response to cost constraints, trade disruption, COVID and digitalization. Corporate social responsibility and sustainability agendas are forcing companies to rethink their value chains and operating models. We discussed how TP professionals can best navigate these changes.
Rising Out of COVID-19 – MNEs Respond
This session shared practical experience and decisions taken by business in relation to their transfer pricing policies during COVID and beyond including: Changes or otherwise to policies and time frames involved; Documentation prepared to support changes; Preparations for controversy management post COVID; Approach to benchmarking for the COVID period; Experience with tax authorities regarding requests for amendments to unilateral and bilateral APAs.
Advanced Operational Transfer Pricing
Having the right TP model is only half the story. Ensuring the policy is and has been implemented correctly is often the more significant challenge to overcome. The effective tax rate is usually dependent on the outcomes of the transfer pricing policy being implemented across the business, but this is usually a process that the tax team cannot control – but is a key stakeholder. Data and technology are seen as the key to fixing OTP, but is technology the answer? This panel gave practical answers to your OTP issues.
Intragroup Financial Transactions
Both recent OECD guidance and a number of tax cases have focused on the transfer pricing of intra-group financial transactions. In this session we will cover this topic in some detail including: Discussion of the recent UK financial transactions TP case; A review of global case law in relation to financial transactions TP; The interaction of the recent OECD FTT and COVID guidelines, and benchmarking financial transactions over periods of economic turbulence. An essential session highly rated by all attendees.
TP Minds International in Numbers
Attendees from 40+ countries in 2020 making TP Minds International a truly global event
Speakers including policy makers, in-house TP experts and leading advisors
Days of essential TP training delivered in a range of engaging formats such as workshops, debates and panels
2021 SPONSORS & SUPPORTERS INCLUDED THE FOLLOWING FIRMS
Become a partner of TP Minds International 2022
Take this opportunity to align yourself with experts in the field from leading firms at the largest global summit series on Transfer Pricing and International Tax issues, with 500+ international delegates in attendance annually.