The Savoy Hotel was awash with transfer pricing ideas on September 25 and 26. The top corporate tax directors from the largest multinationals, the leading regulators and the best transfer pricing thinkers in the world came together to learn about and debate the latest ideas on related-party transactions.
The sixth in International Tax Review's annual forum series attracted more than 200 transfer pricing specialists, building on previous successful editions in Barcelona, Berlin, New York, Amsterdam and Paris. Delegates includes representatives from SAB Miller, Texas Instruments, IBM, Johnson & Johnson, Fiat, Caterpillar, UBS, Cadbury Schweppes, AstraZeneca, Nike, Halliburton, Credit Suisse, eBay, Xerox, Coca-Cola, JP Morgan Chase and Bank of America.
Hal Hicks, international tax counsel at the US Treasury Department, kicked off the proceedings on day one with his keynote address, giving an inside account of where the US government is going next in transfer pricing.
Hicks also rolled up his sleeves and took part in the first , chaired by Marc Levey from Baker & McKenzie's New York office, which discussed the latest trends in transfer pricing. Sarah Fahy, vice president in Sony's Global Tax Office in London, and Sharon Tan, Dell Asia's corporate tax director for the Asia-Pacific, gave the corporate perspective on doing business in the emerging economies, issues around enforcement as well as the local, regional and global approaches to documentation.
Another member of this panel, Jim Fuller, a partner of Fenwick & West in Palo Alto, came up with the sound-bite for the next two days: "Contracts, contracts, contracts!" Intra-company contractual documentation is becoming increasingly important in defending a transfer pricing stance.
The next panel looked at EU transfer pricing issues. Here Bruno Gibert, revealed outcomes from the meetings of the European Joint Transfer Pricing Forum, which he chairs. In particular, he highlighted the growing role of arbitration in tax dispute resolution. Shell International's Kristin Yoshida, global transfer pricing manager, sharing her EU documentation experiences as well as how advance pricing agreements are changing.
Monique van Herksen from the Amsterdam office of Baker & McKenzie, moderated a fresh discussion on the first afternoon on how indirect taxes interact with transfer pricing. Liu Ping from the World Customs Organization in Belgium gave a regulatory perspective while Carmine Rotondaro, worldwide tax manager for the Gucci Group and Angela O'Hara, Vodafone's group value-added tax manager, talked about the differences and similarities in practice between a customs analysis, a value-added tax analysis as well as a transfer pricing one.
The final panel on the first day looked at how to handle transfer pricing controversies. Chaired by Len Terr of Baker & McKenzie in Washington, DC, Paul Mulvihill, dispute resolution adviser at the OECD Centre for Tax Policy and Administration in Paris, provided a look into the organization's project on dispute resolution alternatives. Werner Stuffer, Siemens' global tax director, shared his experiences of various tax authorities.
The first two panels on the second day tackled intangibles. The first covered the legal issues surrounding transfer pricing intangibles with advice and practical tips from Jacqueline Leimer, vice-president and associate general counsel for Kraft Foods in the US, as well as Genevieve Murtaugh, GE Capital's head of EMEA tax.
The next panel, chaired by John Peterson from Baker & McKenzie's Palo Alto office, covered the economics of intangibles. Richard Boykin, executive partner of global markets, tax at KPMG as well as Isabel Verlinden, a tax partner with PricewaterhouseCoopers in Belgium, delivered lively debate on the contested points. Lee Corrick, assistant director of international corporate tax at HM Revenue & Customs explained how the UK tax authorities perceive and evaluate intangibles.
Caroline Silberztein, head of transfer pricing at the OECD in Paris, attracted many delegates to the panel that followed, which covered her organization's initiatives and business restructurings. Timothy McDonald, vice-president for finance and accounting at Procter & Gamble in the US, also provided some techniques on the transfer pricing implications of business re-organizations.
The final panel on day two was one of the best of the two days. It was jammed with top-notch in-house transfer pricing talent with lessons to share. Moderated by Levey, the line-up included Bas de Mik, deputy tax director at ABN AMRO in the Netherlands, Rich Goldberg, director of global transfer pricing at Citigroup, Julian Fortuna, vice-president and general tax counsel at Intercontinental Hotels and Sylvie Puech, senior vice-president of taxes for LVMH Louis Vuitton Moet Hennessy.
The message heard loud and clear over the two days was that companies need three things to protect their transfer pricing decisions: contracts, contracts and contracts. SC
|Who's who in the speaker line-up|
|1. Bas de Mik, deputy tax director, ABN AMRO, Netherlands|
2. Timothy McDonald, vice-president finance and accounting – global taxes, Procter & Gamble, US
3. Genevie Murtaugh, head of EMEA taxes, GE Capital, Netherlands
4. Bruno Gibert, partner, CMS Bureaus Francis Lefebvre, France & chairman of the Joint EU Transfer Pricing Forum, France
5. Monique van Herksen, Partner, Baker & McKenzie, Netherlands
|6. Sharon Tan, corporate tax – Asia-Pacific, Dell Asia, Singapore and Jorge Narvaez Hasfura, partner, Baker & McKenzie, Mexico|
7. John Peterson, partner, Baker & McKenzie, US
8. Len Terr, partner, Baker & McKenzie, US
9. Richard Boykin, executive partner - global markets tax, KPMG, UK
10. Richard Fletcher, economist, Baker & McKenzie, UK
11. Carol Dunahoo, partner, Baker & McKenzie, US
|Who's who in the speaker line-up|
|1. Mike Gaffney, global co-head of tax, Merrill Lynch, US|
2. Keynote speaker - Hal Hicks, international tax counsel, Treasury, US
3. Montserrat Trape Viladomat, deputy head, Regional Office of the National Bureau of Inspection, Spain
4. Isabel Verlinden, partner, PricewaterhouseCoopers, Belgium
5. Rich Goldberg, Director of Global Transfer Pricing, Citigroup, US and Susan Tom, international tax counsel, Xerox, US
|6. Marc Levey, partner, Baker & McKenzie, US|
7. Caroline Silberztein, head of transfer pricing, OECD, France
8. Lee Corrick, assistant director, UK international corporate tax, HM Revenue & Customs, UK
9. Mukesh Butani, partner, BMR, India
10. Holly Glenn, Senior Economist, Baker & McKenzie Consulting, US
11. Pierre-Yves Bourtourault, partner, Baker & McKenzie, France
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