On 30 November 2018 the successful Taxand Global Transfer Pricing Conference 2018, which was hosted by Taxand Netherlands, was held in Amsterdam. Please find below the agenda for that day, including links to the presentations.
- Introduction – by Jimmie van der Zwaan (Taxand Netherlands)
- An update on the current TP landscape and developments within the OECD – by Marlen Sáenz (Head of TP Unit, OECD)
- Hot topics in TP audits – by Einari Karhu (Taxand Finland); Michael Puls (Taxand Germany); Renáta Bláhová (Taxand Slovakia)
Over the recent years tax disputes in cross-border matters have increased rapidly. The development has been even more rapid in transfer pricing following the OECD BEPS work and updated OECD TP Guidelines. The panel had a discussion on the topical aspects recurring in transfer pricing disputes in different countries. The focus is on the issue through case examples and aim to offer a practical view to businesses and practitioners on transfer pricing aspects to take into account in one’s daily work.
- An update on country-by-country reporting and the impact of the exchange of information on Transfer Pricing – by Marcel Hanibals and Willem-Jan van Veen, Country-by-country reporting team, Dutch Tax Authorities
- Transfer Pricing regarding loans and financial instruments – by Stefano Bognandi (Taxand Italy); Deyan Mollov (Taxand UK); Anne Carole Chapuis (Taxand France); Andreas Medler (Taxand Luxembourg)
This panel had a discussion on the application of the arm’s length principle to financial transactions, with taking into account the OECD public discussion draft, published in July 2018. The panel provides an overview of the OECD suggested approach and its practical implications for taxpayers, as well as a comparison between the current practices applied in the UK, France, South Africa and Italy.
- DEMPE – implications for Transfer Pricing regarding IP – by Margaret Critzer (Taxand USA); Hendrik Blankenstein (Taxand Switzerland); Clemens Nowotny (Taxand Austria); Christina Storm (Taxand Germany)
This panel has discussed the practical applications and difficulties faced in applying the DEMPE functions, specifically relating to the ownership of intangibles. It covers the definition of IP, the allocation of the economic ownership of IP based on the DEMPE and difficulties in applying DEMPE across industries.