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March 3rd, 2016 Kyiv, Ukraine Complying with Transfer Pricing Regulations: Practical Aspects

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Page 1: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

March 3rd, 2016

Kyiv, Ukraine

Complyingwith Transfer Pricing Regulations:Practical Aspects

Page 2: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

ORGANISERS’INFORMATION

Hosting BranchIFA Ukraine

IFA Ukraine is the Ukrainian branch of the International Fiscal Association (IFA). IFA Ukraine is a non-profit organization established in Ukraine in 2007. IFA Ukraine was officially recognized by IFA at the 61st IFA Kyoto Congress during September 2007.

IFA Ukraine is the only organization in Ukraine dealing exclusively with international tax matters.

IFA Ukraine has grown in a short time to over 50 members.

www.ifa-ukraine.org

Central IFA

International Fiscal Association (IFA), Netherlands, is the only non-governmental and non-sectoral international organization dealing with fiscal matters over the globe. IFA brings together more than 12,000 practitioners, tax officials and academics from 111 member countries, involved in and concerned with taxation of international transactions and comparative study of tax laws.

Based in Rotterdam, IFA, since its foundation in 1938, has provided, in conjunction with the activities of each country branch, a blend of comprehensive research of international taxation and the development of programs and initiatives of current practical importance.

www.ifa.nl

INVITATION TO SEMINAR

Dear Colleagues!

IFA Ukraine takes a pleasure of inviting you to its first in 2016 educating seminar, dedicated to practical aspects of complying with TP regulations. Senior-level TP specialists will cover latest developments in local and international practice with regard to Transfer Pricing. Seminar agenda will be focused on local specifics of TP methods application, recent court practice on TP issues, availability of information sources and their advantages, as well as on substantiation of transfer prices in intragroup transactions. We invite you to benefit from the offered opportunity and to join us in our professional discussions.

Sincerely,

Olena Voznyuk

IFA Ukraine President

Page 3: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

SEMINAR SPEAKERS

Voznyuk, Olena

President, IFA Ukraine

Olena is a Tax and Legal Partner at Nexia DK. Olena has more than 12 years of experience in advising multinational and domestic clients on tax structuring of inbound and outbound investments, M&A structuring, pre-acquisition and post-acquisition restructuring, Transfer Pricing etc.

Olena served as a tax partner and senior tax lawyer for the leading Ukrainian law firms. She also worked as tax consultant at PwC Kyiv. In February 2014 Olena was elected as the President of the Ukrainian branch of International Fiscal Association. Olena is a member of the Public Council to the State Fiscal Service of Ukraine.

Vrublevska, Larysa

Partner, EUCON

Larysa Vrublevska is a partner and head of accounting and tax accounting practice, transfer pricing practice, electronic and mobile commerce practice of the International Legal Center EUCON.

Larysa specializes in tax consulting, tax planning, transfer pricing, business restructuring and accounting.

She is an author of publications in professional media, and regularly takes part in conferences, forums and round tables.

Rylovnikov, Dmytro

Associate, DLA Piper

Dmytro Rylovnikov, Associate at the Kyiv office of DLA Piper, has over 7 years of experience in taxation. He is experienced in advising Ukrainian companies and multinational groups on topics of Ukrainian domestic taxation and on various tax aspects of cross-border transactions and restructurings. In his practice he is focused on corporate profit tax, transfer pricing and VAT, in course of which he analyses and comments different set-ups and transactions, identifies risks and advises how to mitigate them. Dmytro has received series of extensive trainings on transfer pricing and transfer pricing projects are one of key areas of his expertise. He participated in various transfer pricing projects including planning, strategic analysis and development of transfer pricing documentation for clients from various sectors of economy.

Dmytro has successfully completed a number of transfer pricing projects for many companies, including EPAM, Maersk, Omya, Recordati, Comparex, Carlsberg, Sanofi, Studio Moderna, Stockmann, Alcatel Lucent, Bayer and many others. Dmytro is mainly involved in projects within FMCG, IT and pharmaceutical sectors.

He is fluent in English, Russian and Ukrainian

Tupchii, Oleg

KPMG Ukraine

Oleg Tupchii is a Senior Transfer Pricing Consultant at KPMG Ukraine. He is involved in advising local and international firms on transfer pricing issues and has experience in preparing and adapting master files according to legislative requirements in Ukraine, Russia and the Netherlands.

Oleg also provided recommendations on amendments to Art. 39 of the Tax Code of Ukraine. He holds a Master’s degree in Finance from National University of Kyiv-Mohyla Academy.

Blazhko, Roman

Senior Associate, Lavrynovych & Partners Law Firm

Nikolayko, Anna

Assistant Manager, PwC Ukraine

Roman has 13 years of experience in practicing law, and is one of Ukraine’s leading experts in taxation; he advises on all aspects of tax planning, Ukrainian and international taxation, tax issues in real estate, import and export of goods, tax and customs inspections. Roman has also worked on a number of complex merger and acquisition projects with regard to tax structuring of transactions, including selection of the most optimal jurisdictions for the transaction parties in terms of taxation.

Roman Blazhko has vast experience in appealing against tax decision notices in administrative proceedings, representing clients’ interests in administrative courts of all instances in connection with appeals against tax decision notices, acts or omissions of tax and customs authorities.

Anna is an Assistant Manager with the Tax and Legal Services practice of PwC Ukraine, having more than seven years experience in providing tax services to local and multinational companies, including tax consultancy assignments, tax due diligence, tax reviews and audits.

Over the past several years, Anna has focused on transfer pricing services, thus, gained substantial expertise in preparing transfer pricing documentation, as well as adaptation of global documentation to Ukrainian legislation.

Anna was part of a team that advised the State Fiscal Service of Ukraine and the Ministry of Finance of Ukraine on improving TP legislation in Ukraine based on European best practices.

Page 4: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

11:00 – 11:30 Networking Coffee Break

11:30 – 13:00 • TP Report: How To Reflect Specific Business Transactions?

• TP Documentation: Preparation of High-quality File and Most Important Things to Pay Attention

• BEPS: Action 13

• Recent Court Practice in Transfer Pricing Cases

Thursday, March 3rd, 2016

09:00 – 09:10 Welcome Address

9:10 – 11:00 • Application of TP Methods: Examples, Sources of Comparable Transactions, Calculation of Arm’s Length Range

• Information Sources: Availability Issues, Advantages of Usage

• Substantiation of Transfer Prices in Intragroup Transactions

• Functional Analysis As a Basis For Selection of Transfer Pricing Method

General Partners Information Support

www.ceelegalmatters.com

Panelists:

Oleg Tupchii, KPMG

Dmytro Rylovnikov, DLA Piper

Anna Nikolayko, PwC Ukraine

Panelists:

Oleg Tupchii, KPMG

Larysa Vrublevska, EUCON

Roman Blazhko, Lavrynovych & Partners

Page 5: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

GENERAL INFORMATION

Official Website

For detailed and updated Seminar information, we invite you to visit the IFA Ukraine website at  ifa-ukraine.org

Official language

The Seminar language will be Ukrainian.

Venue

KPMG (Business center “Senator”, 32/2 Moskovska St.), Kyiv, Ukraine.

Sponsorship

If you are interested in sponsorship opportunities, please contact IFA Ukraine at [email protected].

Registration Office

For inquiries regarding registration and accommodation, please contact:

IFA Ukraine Tel.: +38 096 407 89 72 Email: [email protected]

Registration

We invite you to register online.

To  activate online registration link please click here .

Registration Fee

IFA Ukraine Members – free; Non-members - UAH 2,000

Registration Inclusions

Seminar registration includes participation in sessions, electronic access to technical papers and refreshments during seminar hours.

Payment Order IFA Ukraine will email the invoice upon receiving electronic registration.

All charges related to payments by bank transfers must be covered by the Participants.

Seminar hours

9:00 – 13:00

Page 6: Complying with Transfer Pricing Regulations: Practical Aspectsifa-ukraine.org/files/static/TP_March_3_2016.pdf · Kyoto Congress during September 2007. IFA Ukraine is the only organization

General Partners

Hosting CompanyOfficial Service Provider Official Legal Partner