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Cross-Border Transactions
Virtual Tax Summit
What’s happening in international tax and why you need to care
March 13 | 8:30 GMT 
Join Barry Larking for the opening session where he will be addressing questions such as: Do holding companies have a future? How disruptive will digital taxes be? Does the EU blacklist matter? Will America be great again? What happened to the MLI?
Intangibles post-BEPS
March 13 | 10:00 GMT 
Kestutis Rudzika from RoyaltyRange will talk about OECD BEPS and other developments relating to intangibles. He provides practical guidance on determining the ultimate entity entitled to returns derived from the exploitation of intangibles, and discusses on the importance of DEMPE analysis and how it is amplified by the CbC reporting and other requirements.
Transfer Pricing Aspects of US Tax Reform
March 13 | 14:00 GMT (09:00 EST)
Benjamin Miller, PhD from Bennett Thrasher discusses transfer pricing strategies in managing two significant features of the U.S. Tax Cuts and Jobs Act of 2017 - Base Erosion Antiabuse Tax (the BEAT) and the Global Intangible Low Tax Income (the GILTI) provisions. 
Taxation of Digital Business Models
March 13 | 15:30 GMT (10:30 EST)
Digitization has fundamentally changed the way businesses carry out their activities globally. While the digital disruption has affected almost every area of doing business, it is posing a particular challenge to the international tax framework. Dr. Chand discusses these challenges, and provides his take on taxing digital business models.
Q&A on Digital Taxation
March 13 | 16:00 GMT (11:00 EST)
Following, Dr. Chand's presentation on taxing digital business models,Tatiana Falcao from the United Nations, Barry Larking and Dr. Chand discuss on the current trends in digital taxation, unilateral measures, developments at the EU, OECD and UN level. The speakers will also provide their insights in devising rules that can address the problems caused by the digitization of the traditional ways of doing business.
Q&A on Customs Valuation and Transfer Pricing
March 13 | 19:30 GMT (14:30 EST)
Customs and tax authorities pursue different objectives in assessing the value of goods traded between related parties. Nonetheless, in pursuit of efficient global supply chains, there is a growing need for better alignment between TP and customs valuation.

Leonardo Macedo from Brazilian Revenue Authorities and Kriti Velji from New Zealand's Inland Revenue Department share their insights on the interaction between TP and customs valuation. Kriti and Leonardo, along with Brigitte Baumgarnter will discuss the WCO Guide to Customs Valuation and TP, relevant case studies, customs valuation methods compared to OECD TP methods, as well as the most recent Hamamatsu CJEU  C-529/16.
Treatment of Loans in Switzerland and Germany from a TP Perspective
March 14 |10:00 GMT 
Dr. Peter Happe and Retro Giger from GHM Partners discuss on the recent TP developments in Switzerland and Germany respectively, in the context of the BEPS project. 

The speakers share their practical experience in tax and transfer pricing treatment of loans in Switzerland and Germany and how recent developments in the international tax landscape are affecting intra-group financing in these countries. 

Dr. Peter Happe and Reto Giger will be joined by Kestutis Rudzika from RoyaltyRange for a hands on demonstration on database searches for external comparable loans.
A Step-by-Step Guide to Value Chain Analysis
March 14 | 12:30 GMT
Dr. Oliver Triedler from TP&C will demonstrate how to best utilize Excel tools to simplify analysis and compile consistent and focused transfer pricing documentation. Dr. Oliver reviews prominent OECD case studies and illustrates in practice how to conduct a pragmatic value chain analysis.
EU State Aid and APAs
March 14 |14:00 GMT (09:00 EST)
Dr Mario Tenore of Maisto & Associates discusses recent EU Commission’s investigations on State aid and tax rulings. The EU Commission has taken the view that tax rulings confer a selective advantage upon its beneficiaries insofar as they lead to a lowering of the tax burden by deviating from the tax that the beneficiaries would otherwise be obliged to pay under the general corporate tax system. He will also illustrate the way in which various decisions released by the EU Commission interpret “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”.
Advanced TP strategies: Resolving 5 Hot-Button Transfer Pricing Disputes
March 14 | 16:00 GMT (11:00 EST)
MNEs worldwide have seen a spike in the number and complexity in TP disputes. Robert Feinschreiber of Charles River Associates reviews 5 hot button TP disputes and covers market concentration and intangible migration, coping with tax haven and foreign trust over-structuring, addressing a production activity that creates multiple distribution chains, how gray marketing impacts transfer pricing, and using the profit split arrangement for loans.
Implementation in Practice of the PPT in the MLI
March 14 | 17:30 GMT (12:30 EST)
Article 7(1) of the MLI contains provisions related to the prevention of treaty abuse, including treaty shopping that correspond to changes proposed in the BEPS Action 6 Final Report. Tax Agreements of many countries include ‘purpose provisions’ with respect to specific benefits, generally royalties, interests and dividends, although there is no ‘catch-all provision’. These provisions might be replaced by the ‘Principal Purpose Test’ provision of Article 7(1). In this session, Mario Livio Gomes from University of Rio discusses on the challenges in implementing the PPT in practice and how to overcome them.
The AI Technologies and Augmentation of Tax Advisors’ Work: Starting with Tax Treaty Abuse
March 15 | 8:30 GMT 
The current avalanche of new anti-avoidance rules triggered by the BEPS projects and its derivatives, such as the ATAD and domestic anti-BEPS measures, unprecedentedly increases the complexity of tax laws as well as difficulties with tax compliance and tax supervision. The PPT is one of the most prominent examples of such rules with the potential to become a legal conundrum and a real obstacle to frictionless global tax compliance. But what if taxpayers, tax authorities, and courts would be supported in addressing treaty abuse via the PPT with artificial intelligence (AI)? Dr. Kuźniacki will aim to prove the thesis that developing an AI based on identifying fact patterns relevant for economic substance and non-tax business purposes of a taxpayer’s arrangement or transaction could contribute to an efficient and effective applications of the new major anti-tax avoidance rule: the PPT under the MLI. 
Overview of TP Developments in Luxembourg
March 15 | 10:00 GMT 
In this session, Filip Vukovic from PwC provides an overview of Luxembourg TP developments with a focus on the new Luxembourg IP regime. Filip will also share his insights on B2B financing structures, the application of the new general TP rules, lessons learnt from the first CbCr submissions, overview of the market and link with the IP regime. 
BEPS and TP Developments in the MENA region
March 15 | 12:30 GMT
Until recently, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing are not high topics on governmental agendas. Safae Guennoun from EY will cover recent economic trends in the MENA region, as well as the OECD initiative on the BEPS project, which have encouraged governments in the region to adhere to important international tax framework agreements as well as to consider updating their tax legislation in this respect.
Taxation of Cryptocurrencies
March 15 | 16:00 GMT (11:00 EST)
Learn about this ever changing landscape and the gap between new taxable events in cryptocurrency transactions and the regulations needed to support them. Kirk Phillips, CPA will focus on US taxation, however defining the unique events in cryptocurrency are universally important regardless of how a jurisdictions applies the respective rules. Chain splits like bitcoin and bitcoin cash, airdrops and giveaways are all unique events. What are they and how should they be taxed? What accounting method should be used to calculate capital gains and losses? When is cryptocurrency considered ordinary income vs. capital gain income? Why is cryptocurrency considered property for taxations purposes? What accounting method should be used to calculate capital gain income?
Value Creation Analysis under a TP perspective
March 16 | 10:00 GMT 
The concept of Value Creation has gained a lot of attention from the transfer pricing community in the last year. The inclusion of this term in the new Transfer Pricing Guidelines presents a new challenge for transfer pricing practitioners. Brigitte Baumgartner applies Michael Porter’s value creation approach in a pragmatic way, and offers an alternative to Multinational Enterprises for aligning transfer pricing to companies strategies.
TP Developments in the Baltic Region
March 16 | 12:30 GMT 
In January 2018, the Lithuanian Ministry of Finance published a discussion draft on the introduction of new Transfer Pricing Rules. Vykintas Valiulis of Grant Thornton explains the implications of the new rules such as mandatory preparation of transfer pricing documentation until the 6th month following the financial year-end, for each transaction exceeding 30 thousand EUR, for each entity which total turnover is more than 3 million EUR. He also covers TP developments in Latvia and Estonia and what the future looks like for the region in this regard.
Advanced TP Strategies: Resolving 5 Hot-Button Transfer Pricing Disputes
March 16 | 16:00 GMT (12:00 EST)                          CPE Eligible       
MNEs worldwide have seen a spike in the number and complexity in TP disputes. Robert Feinschreiber of Charles River Associates reviews 5 hot button TP disputes and covers market concentration and intangible migration, coping with tax haven and foreign trust over-structuring, addressing a production activity that creates multiple distribution chains, how gray marketing impacts transfer pricing, and using the profit split arrangement for loans.
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International Tax and Transfer Pricing Sessions
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 Cross Border Transactions Virtual Tax Summit
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