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Digital revolution – Spotlight on tax and TP issues in TMT

Todd Wolosoff, global transfer pricing leader; Kristine Riisberg, Americas transfer pricing technology, media and telecommunications industry leader; and David Cobb, EMEA transfer pricing technology, media and telecommunications industry leader

On behalf of our Deloitte tax colleagues that focus on tax and transfer pricing issues within the technology, media and telecommunications (TMT) industry, we are pleased to present this selected collection of thought papers on industry developments and issues.

While many readers may have some knowledge of issues within this industry, we know that one of the key challenges that the TMT industry faces is addressing the breadth of significant tax, transfer pricing, and restructuring issues that are specific to it. Therefore, we begin our guide with a primer on the media and entertainment industry supply chain ranging from production, distribution (theatrical, home entertainment and streaming) to pipeline and packaging, and follow on with an overview of the potential opportunities and pitfalls as a result of the telecom convergence. We address transfer pricing fundamentals, and transfer pricing issues specific to the TMT industry in an attempt to broaden the general knowledge base of international tax professionals or others interested in this revolutionary industry as it is going digital. Next we turn our attention to the challenges of implementing and tracking transfer pricing policies in the continuously evolving technology sector. We have also included an overview of recent tax developments for selected countries that have a significant or expanding presence in today's TMT industry, and address location specific advantages in places like China and India. Finally, we highlight the importance of building a flexible global business platform from an international tax perspective and comment on the VAT consideration for e-commerce.

Given the complexity and variety of tax issues within this industry, this guide should be the starting point rather than the finish line for your TMT industry related transfer pricing and tax inquiries. For more information regarding transfer pricing issues in specific countries, and about Deloitte's tax practice in those jurisdictions, please refer to the list of Deloitte member firm contacts contained in Deloitte's 2013 Global Transfer Pricing Country Guide, which can be found at http://www.deloitte.com/view/en_GX/global/services/tax/cross-border-tax/transfer-pricing/87f08ed08affd110VgnVCM100000ba42f00aRCRD.htm

We hope you find our publication interesting and, more importantly, of practical use, and we invite you to contact our leading team of professionals or your local Deloitte contact if you have any questions.

Yours truly,

Todd Wolosoff
Global Transfer Pricing Leader

Kristine Riisberg
Americas Transfer Pricing TMT
Industry Leader

David Cobb
EMEA Transfer Pricing TMT
Industry Leader

Biography

Todd Wolosoff
Global and US Managing Partner, Transfer Pricing Group
Deloitte Tax LLP

Tel: +1 212 436 4313
Email:twolosoff@deloitte.com

Experience
Todd Wolosoff is the global and US managing partner for Deloitte's Transfer Pricing Group, and a tax partner in the New York City office. He has over 25 years of experience as a partner in representing multinational corporations in transfer pricing and international tax matters. Todd was promoted to his current roles in 2012 and 2011, respectively. Previously, Todd was the partner-in-charge of transfer pricing for the northeast US and the leader of the Tri-State Transfer Pricing Group since its inception in 1990. He is a founding member of the Deloitte Tax National Transfer Pricing Leadership Group.

In Todd's global leadership role, he is responsible for creating and implementing strategy and providing vision and leadership to Deloitte's nearly 2,000 transfer pricing professionals worldwide. Todd also serves as the leader of the Global Transfer Pricing Leadership Group that meets actively throughout the year. Todd is also an active member of the DTTL Global Services Council.

In Todd's US transfer pricing leadership role, Todd is responsible for all aspects of the US Transfer Pricing Group including strategy, operations, hiring, and human resources. Todd has approximately 50 partners, principals, and directors, and hundreds of professionals as part of his team. Todd is the leader of the US Transfer Pricing Leadership Group, and is an active member of the Deloitte International Tax Leadership Group and the Deloitte US Tax Executive Group.

Todd serves as an adviser to several of the world's largest multinationals and has conducted numerous transfer pricing planning studies in virtually all industries, with a particular focus on pharmaceuticals, electronics, financial services, consumer products, automotive, TMT, and fashion and beauty products for both inbound and outbound taxpayers. He has been recognised by Euromoney as one of the world's leading transfer pricing advisers in each of the years the survey has been conducted, and was one of four Deloitte Tax partners selected by Mondaq in its survey of the top attorneys in the US. Todd is also recognised by the International Tax Review as one of the world's leading tax advisers.


Biography

Kristine Riisberg
Principal
Deloitte Tax LLP

Tel: +1 212 436 7917
Email:kriisberg@deloitte.com

Kristine is a Principal in Deloitte's New York office. She has more than 15 years of transfer pricing and international tax experience with Deloitte and spent four years in Deloitte's Washington National Tax Office. Kristine 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 in the following industries: media and entertainment industry, telecommunications, digital, computer software, semiconductors, publishing, oil and gas upstream and field services sectors, power generation and renewable energy, chemical industries, healthcare and medical industry, financial services, automotive and automotive suppliers, quick service restaurants, travel industries, consumer goods, and commodities industries.

Kristine has with her international background and experience working in Deloitte transfer pricing teams in Copenhagen and London build up an extensive knowledge of global transfer pricing matters. Kristine is the Americas transfer pricing leader of the Technology, Media & Telecommunications industry programme. She assumes the global lead tax partner role for the World's largest container shipping conglomerate, the global lead TP role for a U.S. based Media Conglomerate and the U.S. lead TP role for the largest European headquartered Consumer and Industrial Goods Conglomerate.

Kristine has given numerous speeches and presentations at the American Conference Institute, Tax Executives Institute, BNA, Atlas, Thompson Reuters, CITE, Deloitte Debriefs and Conferences on transfer pricing issues.

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

Education

  • Graduate Diploma in Business Administration (Finance), Copenhagen Business School, 2004
  • Master Degree in Laws (LL.M), University of Copenhagen, 1997
  • Studied for her final major subjects at George Washington University – School of Business, 2004
  • Legal studies at the University of Oxford, 1994

Biography

David Cobb
Lead Partner
Deloitte UK

Tel: +44 20 7007 2996
Email:
dcobb@deloitte.co.uk

Experience
David Cobb is the lead partner in the London arm of Deloitte's UK transfer pricing team. Having previously established and led the UK Research & Development tax relief team, and also the global tax relief, grants and incentives service line David's focus has always been predominantly on the Technology sector where he serves a range of clients from large multinational groups to smaller, early stage but high growth companies. David currently represents Tax on the UK firm's Technology industry leadership group and is the EMEA Transfer Pricing leader for Technology, Media & Telecoms.


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