presents
TP Aspects of Financial Transactions
TP Aspects of Financial Transactions
virtual tax summit
virtual tax summit
Join discussions with our leading speakers at this two-day online event
 addressing key TP aspects of financial transactions
 from a topical and jurisdictional perspective.

Join discussions with our leading speakers at this two-day online event addressing key TP aspects of financial transactions
 from a topical and jurisdictional perspective.

October 23 - 24, 2018
Online
Featuring
Why Attend?
On 3 July 2018, the OECD released the first public discussion draft on the transfer pricing aspects of financial transactions. Almost 1,000 pages of comments submitted by 70+ commentators clearly demonstrate the significance of this topic. 

In October 23-24, 2018, we have invited leading TP professionals to address specific issues related to the pricing of intra-group loans, cash pooling, guarantees and captive insurance, as well as to provide their perspectives on selected jurisdiction and regions.

Don’t miss your opportunity to have all your questions answered in these live presentations. 

Sign up now and attend the live sessions for free!
Tax Developments and Outlook
Representatives of tax authorities, institutions and firms will discuss  developments, status and outlook of international tax trends. These sessions will address OECD developments, US Tax Reform, and EU trends. 
Technical Sessions
Technical sessions are crafted to be useful and actionable for both experienced in-house professionals and advisers. These sessions will cover workshops and presentations in TP and International tax.
Case Studies
Speakers will share insights, tactics and strategies from their own projects or use case studies for enhanced attendee engagement and active learning.
Interactive
Ask the speaker for advice during the Q&A, suggest a topic, or network with other like-minded tax professionals virtually.
Accessible
Join for free from anywhere. All you need is an internet-connected device. Forget about travel and hotel cost.
Flexible
Watch all sessions live or on-demand until March 16 free of charge at your own convenience. Want lifetime access to all sessions and bonuses? Get Lifetime Access. 
Speakers
Learn from the top professionals in the field with subject-matter expertise in financial transactions
Theo Elshof
Managing Director
Amanda Pletz
Associate Director
Arnas Laurynas
Executive Director
Stephen Labrum
Principal Tax Advisor
Gaspar Lopes Dias
Tax Adviser
Shannon Smit
Founding Director
Kestutis Rudzika
Executive Director
Raffaello Fossati
Head of Transfer Pricing
Reto Giger
President of BoD & Partner 
Adriana Calderon
Specialist
Gökçe Gücüyener
Head of Transfer Pricing
Justinas Laniauskas
Manager
Katja Lötscher
Tax Adviser 
Hong Chuan Tan
Specialist
Donal O'Connell

Managing Director
IP Specialist
Adjunct Professor

Karen Holste

Independent Tax Advisor
Tax Litigation


Radomir Graj

Founder of Taxjobz
Senior Tax Manager at PepsiCo
Head of EMEA Tax

John Dar

CEO of Intercompany Software
Transfer Pricing


Barry Larking

Donal O'Connell


Donal is the Managing Director of Chawton Innovation Services, a company offering consultancy, education and software solutions in the areas of innovation and intellectual property management.

In the past years, his client base has included leading universities, global IP service providers, IP Firms, global telecoms companies, a compliance firm, global chemical companies, a global food and beverages company, a global heavy engineering company, one of the big four, and a variety of SMEs.





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Barry Larking

Karen Holste


Karen has worked with tax advisory and tax litigation for more than 20 years, both with the Danish National Tax Tribunal, with Big 4 companies and as an in-house CIT Lead and Legal TP responsible in private companies, both smaller growth companies and some of the biggest Danish companies, all working globally. Karen has a background as an attorney, thus using her legal skills when acting as an advisor. 

The systematic approach is reflected in the strategies planned with the clients when securing the tax risk position going forward. Currently, Karen is working to establish new methods and principles for aligning the work prepared by external tax advisors with the core business lines within the company group. This includes technical systems to support and manage tax risks and the tax litigation processes cross border to secure cross group alignment on tax audit management.

Barry Larking

Radomir Graj


Radomir is a seasoned tax professional with substantial in-house tax-legal experience in direct and indirect taxes, tax structuring and strategy, tax accounting, transfer pricing policies and documentation, tax compliance and financial reporting.

He is the founder of Tax jobz.com, a job board matching tax professionals and multinational corporations and professional firms across jurisdictions, including the US, UK and Switzerland. 

Taxjobz network reaches more than 100,000 tax professionals from Linkedin groups Tax Professionals and Tax Opportunities - Taxjobz.com and is the fastest growing job board for tax professionals.

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Barry Larking

John Farooque Dar

John is the co-founder and CEO of Intercompany Software, a solution which offers a new way to manage transfer pricing in medium and large groups with significant cross-border, intercompany trade between group companies. 

Previously, he served as TP lead in financial services for EY and KPMG in Denmark. He is focused on TP software and automation and helps companies execute their transfer pricing policies in a smarter, faster and more accurate way.





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Programme
Tuesday | 23 October 2018
9:30 AM CET
TP Aspects of Intra-Group Loans
Theo Elshof and Arnas Laurynas | Quantera Global
The summit starts with Theo Elshof, who gives an overview of the recently published OECD discussion draft on TP aspects of financial transactions, with a focus on key transactions covered and their proposed treatment as well as implications arising for multinational businesses.

Following Theo, Arnas Laurynas, will address specific issues impacting intra-group loans such as the lender’s and borrower’s perspectives, use of credit ratings, effects of group memberships, pricing approaches to determining an arm’s length interest rate etc.
Theo Elshof is Managing Director and co-founder of Quantera Global. Theo has 30+ years experience in international tax, TP and tax control frameworks in roles as in-house Tax Director, head of the Dutch APA team, and TP Director at a Big-4 firm.

Arnas Laurynas is an Executive Director of Quantera Global and has more than 10 years’ experience in transfer pricing and value chain transformation working with clients in the United Kingdom, across Europe and in other jurisdictions across the globe. 

10:30 AM CET
TP Aspects of Financial Guarantees
Gaspar Lopes Dias | Loyens and Loeff
Gaspar Lopes Dias will follow with a technical session on transfer pricing aspects of guarantee fees. He will cover issues such as explicit, implicit and cross-guarantees, methods in determining arm's length guarantee fees such as the CUP method, yield approach, cost approach, valuation of expected loss approach and capital support method. 

Lastly, he will provide valuable insights on financial transactions transfer pricing from a Luxembourg perspective
Gaspar Lopes Dias is a Tax Adviser in the tax practice group of Loyens & Loeff Luxembourg. He specializes in international taxation and transfer pricing, Gaspar advises on financial transactions (e.g. cash pool, debt pricing) and on intra-group services.


1:30 PM CET
TP Aspects of Captive Insurance
Amanda Pletz | NERA Economic Consulting
Amanda Pletz will provide a technical presentation of TP aspects of captive insurance arrangements. She will kick off with an overview on captives, a look into the OECD discussion draft touching upon these transactions, and lastly offer practical insights on the various methods in determining arm’s length price of captives and pricing of premiums, such as combined ratio and return on capital. 
Amanda is an Associate Director in NERA's Global Transfer Pricing Practice. She specializes in cross border related party transactional pricing and asset valuation issues, with a focus on the financial services sector and financing arrangements.  

3:00 PM CET
Benchmarking Interest Rates
Kestutis Rudzika and Justinas Laniauskas | RoyaltyRange
Kestutis and Justinas will provide a hands-on session on benchmarking arm's length interest rates using the RoyaltryRange loan interest rates database. 

Their session will include all aspects to be considered when benchmarking interest rates, including analyzing the terms and conditions of related party loan arrangement, credit rating analysis, searching for comparable transactions, adjusting uncontrolled transactions for credit risk, tenor, currency risk, country risk, fixed-floating adjustments, etc.
Kestutis is a Transfer Pricing Director and Tax Lawyer at RoyaltyRange. He has extensive transfer pricing experience and specializes in post-BEPS developments, including DEMPE analysis for intangibles.

Justinas is a Manager at RoyaltyRange and is actively involved in the development and quality maintenance of the company's loan interest rates database products.
Wednesday | 24 October 2018
9:30 AM CET
Asia Pacific Perspective
Shannon Smit, Adriana Calderon, Hong Chuan | Transfer Pricing Solutions
The Transfer Pricing Solutions team will provide their insights on the discussion draft as well as on the TP treatment of financial transactions from various jurisdictions across Asia Pacific. 

While all team members will share their experience in the region as a whole, Shannon and Hong will focus on the Australian perspective on the discussion draft and financial transactions in general, whereas Adriana offers her insights from the Singaporean and Malaysian perspective. 
Transfer Pricing Solutions is a boutique transfer pricing firm with offices in Australia, Singapore and Malaysia that apply their experience and expertise in transfer pricing to prepare, document and assist in defending related party transactions internationally.
10:30 AM (CET)
Swiss Perspective
Reto Giger and Katja Lötscher | GHM Partners
Reto and Katja will be sharing their practical insights of the OECD discussion draft from a Swiss MNE angle - such as recommendations with regards to credit rating approaches and pricing methodology, as well as cash pool synergies between Swiss participants. 
GHM Partners AG is an owner-run, dynamic tax and le­gal consulting firm head­quartered in the center of Zug, Switzerland.
GHM Partners advise medium-sized and large compa­nies active in Switzerland and inter­nationally.  Clients include multinational trade and manufacturing compa­nies, real estate compa­nies, financial service providers and HNWIs.
11:30 AM CET
Turkish Perspective
Gökçe Gücüyener | Mazars Denge
Gökçe Gücüyener joins us to offer local insights on the TP aspects of financial transactions from the Turkish perspective.  Her session includes an overview of intra-group financing, including consideration for other taxes, cash pooling arrangements, guarantee fees as well as the TP treatment of derivatives such as hedging, swaps and forward transactions. 
Gökçe Gücüyener is a Partner and Head of the Transfer Pricing Practice at Mazars Denge in Turkey.  Her sector specific knowledge include automotive, logistics, metals, oil & energy, media & entertainment, banking and financial services.
1:30 PM CET
TP Aspects of Cash Pooling Arrangements
Steve Labrum | Baker McKenzie
Steve Labrum will discuss the TP aspects of cash pooling arrangements, with specific focus on the operation of a physical and notional cash pools, rewards to the cash pool leader and cash pool members, application of the same interest rate for all participants, allocation of cash pooling benefits to the depositors and cash pooling guarantees. 
Steve Labrum is Principal Tax Advisor at Baker McKenzie. He has 20 years of experience working for Big Four accounting firms, including 17 years as a partner and as Global Head of Financial Services Transfer Pricing. Steve’s practice covers transfer pricing policy design, business restructuring, global documentation, and controversy with tax authorities. His primary industry focus is financial services, including the full spectrum of banking, investment management and insurance clients.
3:00 PM CET
Italian Perspective
Raffaello Fossati | Fantozzi & Associati
As part of Fantozzi & Associati, Raffaello has been a key contributor to the comments sent by the firm on the recently published OECD discussion draft. He will share his jurisdictional insights on TP aspects of financial transactions in Italy, as well as his commentary on the OECD discussion draft on this matter.
Raffaello is Head of Transfer Pricing at Fantozzi & Associati. His areas of expertise include transfer pricing, international tax, business restructuring and tax dispute resolution. He has previously worked for Ernst & Young as a Transfer Pricing Manager.
Frequently Asked Questions
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Where is this event located?
I can’t attend all the live sessions. Will I get a recording?
Taxcasts, Inc.
2035 Sunset Lake Road, Suite B-2, Newark 19702, Delaware, USA