the meeting place for transfer pricing professionals … · globally, including the latest on the...

Main Conference: February, 25 - 26, 2020Workshops: February 24 2020

The Biltmore Hotel, Miami

THE MEETING PLACE FOR TRANSFER PRICING PROFESSIONALS IN THE AMERICAS

Inspiration70+ Speakers20+ Presentations & Panels

Networking230+ Attendees70% Corporate Delegates20+ Industries Represented

Share Insights and Best Practice Advice on The Latest Transfer Pricing Challenges Affecting the Region

Kay Freund MEDTRONIC

Dilpesh Topiwala IHG

Wade Owen VISA

Sahar Gaya GLENCORE

Niraja Srinivasan DELL

Azedine Assassi GE

https://informaconnect.com/tp-minds-americas-conference/TP Minds @TPSummit

#TPAMERICAS

2To register or for the latest information, please visit: https://informaconnect.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected]

CONTENTS3 Programme at a Glance4 Meet 70+ TP Leaders, Advisers & Policy Makers6 Summit Day One9 Summit Day Two12 Pre & Post-Conference Worshops14 Supporters of TP Minds International 2019

EVENT SCHEDULEMain Conference: February 25-26 2020Workshops February 24 2020

SPONSORS AND EXHIBITORSLEAD PARTNER CO PARTNER

ASSOCIATE PARTNERS

GOLD PARTNERS

SILVER PARTNERS


TP MINDS AMERICAS 2020 PROGRAMME AT A GLANCEMONDAY, FEBRUARY 24PRE-CONFERENCEWORKSHOPS

A choice of 3 highly interactive and technically sophisticated workshop sessions designed to allow you to dive deeper into critical aspects of Transfer Pricing. You will look in detail at the Digital Economy, Transfer Pricing, VAT, and Direct Tax Implications of Global Reform and Arbitration in MAP.

Big Themes• The Tax Challenges of the Digital

Economy• The Art of Tax Wars: Transfer

Pricing, Indirect Tax, and Direct Tax Implications in an Age of Global Disruption

• Arbitration in MAP: How to Avoid Pitfalls and Optimize Outcomes

Key SpeakersLaurie Dicker, BDOTherese Garcia, BDOAngeline Chandra, BDOBob Bamsey, RSMDuncan Stocks, RSMTansy Jefferies, RSMClark Armitage, CAPLIN & DRYSDALE

TUESDAY, FEBRUARY 25MAIN CONFERENCE, DAY 1

Day one of TP Minds Americas kicks off with keynote session from Mayra Lucas, Advisor at the OECD who will be bringing us an update on the latest developments from the Centre of Tax Policy and Administration. We then follow with our policy makers session, where we will be assembling key policy makers and tax authorities from the region to discuss the latest TP developments. In addition to these key domestic and international policy updates, you’ll get to hear from in-house TP professionals on the key issues challenging heads of transfer pricing globally, including the latest on the Digital Economy & the Unified Approach under Pillar 1, Global Supply Chain & Analytics, US Tax Reform, and much more!

Big Themes• Latest OECD Developments• Policy Perspectives on TP & BEPS 2.0• Pillar 1 and the Unified Approach• APAS & MAP• US Tax Reform• Being Audit Ready

Key SpeakersGregory Spring, IRSWade Owen, VISAKatherine Amos, JOHNSON & JOHNSONJoao Braga Ribeiro, SABRE CORPORATIONSonal Majmudar, WORLD BANK

WEDNESDAY, FEBRUARY 26MAIN CONFERENCE, DAY 2

Day two of TP Minds Americas begins with an International TP Case Law Review, taking a deep dive look at key transfer pricing cases over the past 12 months. This is followed by Controversy & Dispute Resolution, which will be bringing together in-house perspectives on best practice when resolving transfer pricing disputes. Further highlights for the day include Latest Developments in Latin America, Automation & Technology, Intangibles and Comparability, TP & Customs and the latest in Intercompany Financing. Not to be missed!

Big Themes• Controversy & Dispute Resolution• Transfer Pricing Developments in

LATAM• TP & Customs Interactions• Automation & Technology• Automation & Technology • Financial Transactions

Key SpeakersSahar Gaya, GLENCORELucia Fedina, CBREAmit Mangla, ALLERGANSoorashree Sadekar, AIGAzedine Assassi, GE


MEET 70+ TP LEADERS, ADVISERS & POLICY MAKERSKatherine Amos Global Head of Transfer Pricing JOHNSON & JOHNSON

Clark Armitage President CAPLIN & DRYSDALE

Azedine Assassi Global Transfer Pricing Leader GE

Bob Bamsey Senior Manager Global Transfer Pricing Services RSM

James Boldenow Head of Tax GRACO INC

Bob Bowne Transfer Pricing Senior Manager BDO

Joao Braga Ribeiro Senior Manager - Transfer Pricing SABRE CORPORATION

Keith Brockman VP Global Tax WELBILT

Scott Campbell Director - International Tax AT-PAC

Angeline Chandra Partner, Transfer Pricing BDO

Jessie Coleman Tax Office Lead IFC

Debora Correa Talutto Group Transfer Pricing Manager & Senior NSA Tax Manager TEMENOS

Terry Coulter Director Global Transfer Pricing AXALTA

Andrew Cousins Director, Transfer Pricing DUFF & PHELPS

Fernando Cruz Managing Director; Transfer Pricing Southeast Region BDO

Steve Cullimore Partner -Transfer Pricing BDO

Paul Daly Transfer Pricing Leader BDO

Barb Derus Partner, Transfer Pricing BDO

Laurie Dicker Technical Tax Practice Leader - Transfer Pricing BDO

Lorraine Eden Professor TEXAS A&M UNIVERSITY

Ariel Efraim Transfer Pricing Leader BDO

Lucia Fedina Global Transfer Pricing Lead CBRE

David Forst Partner FENWICK & WEST

Kay Freund Global Transfer Pricing Director MEDTRONIC

Kevin Gallagher Vice President ANALYSIS GROUP

Therese Garcia Partner, Transfer Pricing BDO

Sahar Gaya Transfer Pricing Lead GLENCORE


MEET 70+ TP LEADERS, ADVISERS & POLICY MAKERSGeorge Georgiev, Ph.D. Senior Director, Transfer Pricing and Economic Analyses SIEMENS

Ami Goldenstein TP Lead for US and LATAM TAKEDA PHARMACEUTICALS U.S.A

Margaretha Haeussler Transfer Pricing NOVARTIS

Tansy Jefferies Principal, International Tax RSM

Monika Loving International Tax Services Partner & National Practice BDO

Jed Larkin Vice President 3M

Kristin Lazar Director Of Tax - Transfer Pricing AMERICAN EXPRESS GLOBAL BUSINESS TRAVEL

Amit Mangla Tax Director ALLERGAN

Kay Freund Global Transfer Pricing DirectorMEDTRONIC

Sonal Majmudar Advisor WORLD BANK

Andrés Motta Partner BASEFIRMA

Fernando Becerra O’Phelan International Taxation and Transfer Pricing Manager SUNAT

Dan McGeown Transfer Pricing Leader BDO

Wade Owen Senior Director, Global Transfer Pricing VISA

Ketan Patel Global Head of Tax Technology MORGAN STANLEY

Chichi Okechukwu International Tax Manager INFOR

Zara Ritchie Head of Global Transfer Pricing Services BDO

Gabriel Romero Partner BASEFIRMA

Damon Pike Principal, International Tax - Customs & International Trade Services BDO

Mark Schuette Transfer Pricing Leader BDO

Gregory Spring Assistant Director (Acting) - Advance Pricing Mutual Agreement Program INTERNAL REVENUE SERVICE

Soorashree Sadekar Associate Director AIG

Duncan Stocks Principal, International Tax RSM

Niraja Srinivasan Executive Director, Tax DELL

Pedro Tobar Transfer Pricing Senior Manager HALLIBURTON

Jared Walls Partner VALENTIAM GROUP

Dan Peters Managing Partner VALENTIAM GROUP


Dilpesh Topiwala VP of Tax IHG

Marco Valdonio Partner MAISTO E ASSOCIATI

Luis Carrillo Transfer Pricing Director BUREAU VAN DIJK

Alan White Managing Principal ANALYSIS GROUP

Nicole Williams Senior Manager, Global Transfer Pricing CELANESE

Steven Dixon Member MILLER & CHEVALIER

Carlos Pérez-Gomez Serrano LATAM Region Lead ROYALTYRANGE

Loren Ponds Member MILLER & CHEVALIER

Fabian Alfonso Managing Director DUFF & PHELPS

Lionel Nobre Vice President, Latin America Tax DELL

Andrea Adler Director VALENTIAM GROUP

Sean Caren Senior Director of Global Transfer Pricing S&P GLOBAL MARKET INTELLIGENC

Steve Allen Director - Global Transfer Pricing MCDONALD’S

Flavia Siuves Tax Director DIAGEO

Mark LudwigNational Leader - Trade & Tariff Advisory ServicesRSM

Moises DoreyDirector - Transfer PricingUNITED TECHNOLOGIES

Joan Hortalà VallvéPartnerCUATRECASAS, GONÇALVES PEREIRA

Brian VincentPartnerECONOMICS PARTNERS

Perry UrkenPartnerECONOMICS PARTNERS

Dan TeigenGlobal Transfer Pricing Senior ManagerMEDTRONIC

MEET 70+ TP LEADERS, ADVISERS & POLICY MAKERS

7

DAY 1 | FEBRUARY 25, 202008:30 Registration & Coffee

09:00 Chair’s Opening RemarksMark Shuette Transfer Pricing Leader BDO

09:10 Setting the SceneLorraine Eden Professor TEXAS A&M UNIVERSITY

09:40

Policy Perspectives on the Transfer Pricing Landscape & BEPS 2.0How are the international organizations and Tax Administrations addressing transfer pricing and the evolving international tax landscape, including BEPS and other developments, and where do they expect them to develop in the future?

Fernando Becerra O´Phelan International Taxation and Transfer Pricing Manager SUNAT




Jared Walls Partner VALENTIAM GROUP

10:30

Quickfire Round: Ask the Policy MakersDon’t miss your opportunity to put your questions directly to our panel of leading tax authorities and policy makers. They will try to address as many of your questions as possible during this session and we would like to remind you these can be submitted in a number of ways. You can:• Ask for the microphone and put your questions live to our panel on stage• Submit a question through our event app and have this answered in real time• Tweet us your question using the hashtag #TPAMERICAS19• Email a complex question in advance to [email protected] so this can be addressed by our

experts at the event having given it careful consideration in the run-up to the event

Fernando Becerra O´Phelan International Taxation and Transfer Pricing Manager SUNAT


Mayra Lucas Transfer Pricing Advisor OECD



11:00 Morning Coffee

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected]

To register or for the latest information, please visit: finance.knect365.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 8

11.25 The Digital Economy: The OECD’s Unified Approach


Katherine Amos Global Head of Transfer Pricing JOHNSON & JOHNSON

Steve Cullimore Partner – Transfer Pricing BDO

Steve Allen Director - Global Transfer Pricing MCDONALD’S

Wade Owen Senior Director, Global Transfer Pricing VISA

12:05

US Tax Reform – In-House Perspectives• With two years of perspective, what has been the most unexpected impact of US tax reform?• What areas of US tax reform have resulted in the greatest challenge for organizations?• Are there areas that still present uncertainty?• How does US tax reform look to the rest of the world in light of the changing global tax landscape?• What’s the outlook for next two years on continued impacts of US tax reform?

Monika Loving International Tax Services Partner & National Practice BDO

Jed Larkin Vice President 3M

James Boldenow Head of Tax GRACO INC

Dilpesh Topiwala VP of Tax IHG

12:45 Lunch

13:45

TP Documentation & CbCR• Recent experiences from the industry• How are tax authorities appearing to be using the data?• Year 3 & 4 post BEPS/CbCR and beyond• The future of the benchmarking analysis• What could/should be the OECD’s next moves?

Pedro Tobar Transfer Pricing Senior Manager HALLIBURTON

Chichi Okechukwu International Tax Manager INFOR

Fabian Alfonso Managing Director DUFF & PHELPS

Kristin Lazar Director Of Tax – Transfer Pricing AMERICAN EXPRESS GLOBAL BUSINESS TRAVEL

Dan Peters Managing Partner VALENTIAM GROUP

Carlos Pérez-Gomez Serrano LATAM Region Lead ROYALTYRANGE

14:35

APAs & MAP• Trends in APAs and MAPs• Best practices in a changing tax world• Impact of MLI, inclusive framework etc• What is the role of MAP in the future?• APAs and MAP beyond the Americas

Marco Valdonio Partner MAISTO E ASSOCIATI

Joao Braga Ribeiro Senior Manager - Transfer Pricing SABRE CORPORATION





15:15

Practical Tips and Advice on being ‘Audit Ready’• What does being audit ready look like post BEPS?• How are tax authorities approaching TP audits?• Economic substance over legal form• OECD TP guidelines to disclose TP agreements

Kay Freund Global Transfer Pricing Director MEDTRONIC

Keith Brockman VP Global Tax WELBILT

Luis Carrillo Transfer Pricing Director BUREAU VAN DIJK

Loren Ponds Member MILLER & CHEVALIER

15:55 Afternoon Coffee and Demo: Digital Transfer Pricing in the 2020s sponsored by

16:15

Global Supply Chain Planning & Analytics• How are companies approaching supply chain planning efforts? - Transfer pricing, indirect tax and operational supply chain initiatives• Finding a holistic solution that can bring financial value and risk mitigation to global companies.

Barb Derus Partner, Transfer Pricing BDO

Moises DoreyDirector - Transfer Pricing UNITED TECHNOLOGIES

Damon Pike Principal, International Tax – Customs & International Trade Services BDO

Dan TeigenGlobal Transfer Pricing Senior ManagerMEDTRONIC

16:55

Permanent Establishments• Managing Permanent Establishment Risk - Are activities that trigger PE risk changing?• PEs in the Digital Economy• Attribution of profits to PE - Practical difficulties in applying the AOA• Latest OECD discussion draft

Andrew Cousins Director, Transfer Pricing DUFF & PHELPS

Perry UrkenPartnerECONOMICS PARTNERS

George Georgiev, Ph.D. Senior Director, Transfer Pricing and Economic Analyses SIEMENS

Flavia Siuves Tax Director DIAGEO

17:35 Chair’s Closing Remarks & Drinks Reception

10To register or for the latest information, please visit: finance.knect365.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected]

DAY 2 | FEBRUARY 26, 2020

08:00

Breakfast BriefingTransfer Pricing Regional UpdateThis session will cover updates from some of the key transfer pricing territories and contain a local perspective on how the changes from the OECD are being effected in local law and practice. The session will be a discussion based panel focused on how regions are responding to current transfer pricing challenges and opportunities along with practical guidance and experience within each of the regions.

Zara Ritchie Head of Global Transfer Pricing Services BDO

Dan McGeown Transfer Pricing Leader, BDO

Ariel Efraim Transfer Pricing Leader BDO

Paul Daly Transfer Pricing Leader BDO

08:40 Registration & Coffee

09:00 Chair’s Opening Remarks Barb Derus Partner, Transfer Pricing BDO

09:10International TP Case Law ReviewThis presentation will provide an overview of recent international transfer pricing cases.


09:40

Navigating the TP Controversy Landscape• The current controversy landscape• Recent tax administration initiatives• Alternative dispute resolution• How are multinationals gearing up to handle disputes?

Sahar Gaya Transfer Pricing Lead GLENCORE

Nicole Williams Senior Manager, Global Transfer Pricing CELANESE

Brian VincentPartnerECONOMICS PARTNERS

Margaretha Haeussler Transfer Pricing NOVARTIS


Joan Hortalà VallvéPartnerCUATRECASAS, GONÇALVES PEREIRA

10:30 Transfer Pricing Developments in Latin America Gabriel Romero Partner BASEFIRMA

Andrés Motta Partner BASEFIRMA

11:10 Morning Coffee

11

11:30

Outcomes in Transfer Pricing Litigation: an Economic PerspectiveRecent tax developments (eg. OECD, BEPS initiative, U.S. tax reform) have elevated the visibility and complexity of Transfer Pricing. The recent appeals of the Medtronic and Amazon transfer pricing matters, underscores the differing opinions that seem to be common in tax matters with notable valuation gaps. This panel will share their perspectives on the role of economists in various transfer pricing and tax controversy matters.

Alan White Managing Principal ANALYSIS GROUP

Kevin Gallagher Vice President ANALYSIS GROUP

Lorraine Eden Professor TEXAS A&M UNIVERSITY

12:10

Transfer Pricing Automation & Technology• What technology solutions are multinationals using?• Designing a successful tax technology strategy• Improving the consistency of compliance processes• Automation and streamlining of tax processes

Ketan Patel Global Head of Tax Technology MORGAN STANLEY

Soorashree Sadekar Associate Director AIG

Debora Correa Talutto Group Transfer Pricing Manager & Senior NSA Tax Manager TEMENOS

12:50 Networking Lunch

13:50

European Transfer Pricing Developments • Anti-avoidance• State Aid can• Mandatory Disclosure Rules• DAC6

Jonneke Dijkstra Tax Adviser LOYENS & LOEFF

14:30Financial TransactionsThis session will explore current transfer pricing issues impacting financial transactions across various industries, with a focus on issues and opportunities around intercompany loans and financial services.

Fernando Cruz Managing Director; Transfer Pricing Southeast Region BDO

Sean Caren Senior Director of Global Transfer Pricing S&P GLOBAL MARKET INTELLIGENCE

Ami Goldenstein TP Lead for US and LATAM TAKEDA PHARMACEUTICALS U.S.A


15:10 Afternoon Coffee

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected]


15:30

Intangibles & Comparability• The current TP of Intangibles landscape• The interplay between BEPS Action 8 and Cost• Sharing/Contribution Arrangements• IP planning in wake of US tax reform• Latest OECD guidance• Comparability challenges and best practice

Azedine Assassi Global Transfer Pricing Leader GE

Andrea Adler Director VALENTIAM GROUP

Steven Dixon Member MILLER & CHEVALIER

Amit Mangla Tax Director ALLERGAN

Lucia Fedina Global Transfer Pricing Lead CBRE

16:10

Transfer Pricing & Customs Interactions• Defending transfer prices as acceptable customs values• Using transfer pricing information to examine related party transactions• Relationships with the in-house customs team• How to in-house TP and customs policies interplay?• Variations in the types of evidence required to support the acceptability of transfer prices as the basis for customs values

Scott Campbell Director – International Tax AT-PAC

George Georgiev, Ph.D. Senior Director, Transfer Pricing and Economic Analyses SIEMENS


Lionel Nobre Vice President, Latin America Tax DELL

16.50 Chair’ Closing Remarks and Close of Conference

CPE POINTS AT TP MINDS AMERICAS 2020Recommended CPE Credits:

• 25 CPE Credits (two main conference days + pre conference workshops)

• 15 CPE Credits (two main conference days only)

• 9 CPE Credits (pre conference workshops only)

CPE SponsorsInstitute for International Research is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the national Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue, Nashville, TN 37219-2417. Web site: www.nasba.org For further information, please Contact: [email protected]


Workshop A (08:30 - 11:30)

The Tax Challenges of the Digital EconomyOverview:• Where are we now and how did we get here?• Review of major milestones and developments• In-depth review of [January-February 2020] developments• How would the [Jan-Feb 2020 proposal] work?• Jan-Feb 2020 Proposal – changes from the November 2019 Unified

Proposal• Case study – how the proposal would be implemented• Discussion of key areas of uncertainty• What happens next?• What is on the OECD calendar for the rest of 2020?• What does our crystal ball say?• Current state of unilateral Digital Services Taxes and similar

measures

Workshop Leaders:

Laurie Dicker Technical Tax Practice Leader - Transfer Pricing BDO

Therese Garcia Partner, Transfer Pricing BDO

Angeline Chandra Partner, Transfer Pricing BDO

Workshop B (11:30 -14:45)

The Art of Tax Wars: Transfer Pricing, Indirect Tax, and Direct Tax Implications in an Age of Global DisruptionOverview:Reforms around the globe are creating a tax battlefield between countries. Join a discussion of transfer pricing, VAT, and direct tax technical topics, using practical examples of the art of a tax professional navigating today’s undulating terrain. Covered topics include:• Overview of the current transfer pricing, tariffs, trade, and VAT

landscapes• Interaction of VAT, tariffs, and transfer pricing• Transfer pricing adjustments and their associated direct and indirect

tax consequences• What’s next? Considering the future of VAT, tariffs, trade, and TP

reform

Workshop Leaders:

Tansy Jefferies Principal, International Tax RSM

Duncan Stocks Principal, International Tax RSM

Bob Bamsey Senior Manager, Transfer Pricing RSM

Mark LudwigNational Leader - Trade & Tariff Advisory ServicesRSM

Workshop C (14:45 - 17:30)

Arbitration in MAP: How to Avoid Pitfalls and Optimize OutcomesOverview:• Gamesmanship in the lead-up to arbitration deadlines and how

to mitigate damage• Positive benefits of arbitration; and some negatives• Expanded use of arbitration within and without the U.S.• A case study

Workshop Leaders:


PRE-CONFERENCE WORKSHOPS February 24, 2020


SUPPORTERS OF TP MINDS AMERICAS 2020LEAD PARTNER

CO PARTNER

BDO is the brand name for BDO USA, LLP, a U.S. professional services firm providing assurance, tax, and advisory services to a wide range of publicly traded and privately held companies. For more than 100 years, BDO has provided quality service through the active involvement of experienced and committed professionals. The firm serves clients through more than 60 offices and over 550 independent alliance firm locations nationwide. As an independent Member Firm of BDO International Limited, BDO serves multi-national clients through a global network of 67,700 people working out of 1,400 offices across 158 countries.

Website www.bdo.com

GOLD PARTNERSAt BaseFirma, we are a team of economists, international tax lawyers, accountants, and financial consultants. With over 650 clients in 30 countries on four continents, BaseFirma has a strong physical presence in all major markets. Our services range from providing transfer pricing documentation, country-specific reports, and audit defense, to tax structuring, implementation of transfer pricing models, and valuation of intangible assets. All services we provide are aligned with local regulations and with recent global initiatives of BEPS environment , such as, the new OECD Transfer Pricing Documentation, Master File, Local File and country by country reports. BaseFirma, the most dominant US transfer pricing firm in Latin America, continues to expand its activities in South America. Our new Sao Paulo office just opened at the JK complex, the distinguished landmark at Vila Olímpia. After 16 years of consecutive growth in the Americas, BaseFirma has strengthened its position as the industry leader in Latin America.

Website basefirma.com

Fulfilling complex transfer pricing requirements can be a daunting task for any multi-national organization. As experts in transfer pricing, Duff & Phelps provides an independent and uncompromised perspective on all aspects including compliance, planning, controversy and implementation. Our team of internationally recognized transfer pricing advisors provide the technical expertise and industry experience necessary to ensure understandable, implementable and supportable results.

Duff & Phelps is the premier global valuation and corporate finance advisor with expertise in complex valuation, dispute and legal management consulting, M&A, restructuring, and compliance and regulatory consulting. The firm’s more than 2,000 employees serve a diverse range of clients from offices around the world.

Website www.duffandphelps.co.uk

The Fenwick & West Tax Group has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100 largest U.S. companies, and over 100 of the Fortune 500 largest U.S. companies in U.S. federal tax matters. We have one of the world’s leading practices in international structuring, transfer pricing, M&A, and controversy. International Tax Review, a leading tax publication, named us “Tax Firm of the Year for the San Francisco Area” eight times in the past 11 years, and “US (or Americas) Tax Litigation Firm of the Year” three times. In 2016, we also were named US West Transfer Pricing Firm of the Year. Our attorneys are among the very best in their field, developing innovative ideas and structures, and publishing thought leading articles. Attorneys in our Tax Group teach the international tax class at both Stanford and Berkeley Law Schools.

Website www.fenwick.com

The Valentiam Group is made up of industry-leading professionals who have worked together for many years. The core of the group has been together for 10 years, and some of our partners have worked together for over two decades. The name Valentiam is new, because we’ve formed a single group of extraordinarily credentialed experts who wish to brand ourselves as one of cohesive group. The company is named after the Latin phrase ad valentiam, “to the value,” to indicate the trusted accuracy of the work we do. Our Partners, Directors, Senior staff, and other professionals have been formed from legacy Big 4 accounting firms and other respected boutique firms specializing in Transfer Pricing and Valuation. Our senior professionals have worked successfully with hundreds of discerning clients. Many of the clients are members of the Fortune 500. We’re highly experienced both domestically and internationally.

Website www.valentiam.com


Increasing complexities and growing transparency considerations in the international business community create tax challenges for corporations with global operations, particularly in light of pending tax reform. With over five decades of experience handling sophisticated cross-border matters for our clients, Caplin & Drysdale’s International Tax Group is well-versed in addressing these challenges. Many of our lawyers formerly held senior roles in the Internal Revenue Service, the Department of Justice, and the Treasury Department, giving insight into how U.S. tax law is administered and enforced. Several had senior in-house positions with leading multinational companies. Our collective experience in government, corporate, and private practice means we bring a unique combination of technical background and tactical judgment to resolving our clients’ most sensitive matters.

Website www.caplindrysdale.com

Founded in 1920, Miller & Chevalier is a longstanding Washington, DC law firm with a global perspective and leading practices in tax, litigation, international, employee benefits, white collar defense, and government affairs. Over the past three years, the firm’s lawyers have represented more than 40 percent of the Fortune 100, one-quarter of the Fortune 500, and approximately 30 percent of the Global 100. Miller & Chevalier is a trusted partner to clients in the United States and around the world, providing solutions to their most complex problems, as well as counsel that enables clients to seize new opportunities.

Website www.milchev.com

SILVER PARTNERSMaisto e Associati is an independent Italian tax law firm established in 1991 with offices in Milan, Rome and London. Our transfer pricing team is composed of high skilled persons that come from different professional backgrounds which makes our law firm one of the best recognized in the field. Maisto e Associati provides the full range of transfer pricing services from the development of the transfer pricing policies, drafting of the documentation through to the negotiation and conclusion of Advance Pricing Agreements with the Italian Tax Authorities. The firm has been consistently ranked for several years by independent researchers as tier 1 Italian tax law firm (Chambers & Partners; The Legal 500; International Tax Review, World Tax).

Website www.maisto.it

Economics Partners provides a comprehensive suite of transfer pricing services to proactively and efficiently manage the ever-changing global legislative and regulatory requirements and the growing potential for audit assessments. Our professionals address the business impact of cross-border transactions, as well as provide effective solutions that improve client profitability and reduce overall global tax liabilities by optimizing intercompany pricing from an operational and multinational tax perspective.

We understand our clients’ objectives and leverage our technical expertise in global transfer pricing principles to identify the proper balance in pricing cross-border transactions. Our ability to complement this expertise with our strategic approach and thorough understanding of international and value-added taxes ensures the highest level of value and delivery of client results.

Website www.econpartners.com

Analysis Group is one of the largest international economics consulting firms, with more than 1,000 professionals across 14 offices in North America, Europe, and Asia. Since 1981, we have provided expertise in economics, finance, tax and transfer pricing, health care analytics, and strategy to top law firms, Fortune Global 500 companies, and government agencies worldwide. Our internal experts, together with our network of affiliated experts from academia, industry, and government, offer our clients exceptional breadth and depth of expertise.

Website www.analysisgroup.com

Bureau van Dijk is now a Moody’s Analytics company. They capture and treat private company information for better decision making and increased efficiency. Its products combine data from regulatory and other sources, including over 160 information providers, to deliver the richest, most reliable private company information, corporate structures, beneficial ownership and deal information in the market. With information on around 300 million companies they are the resource for company data. A key benefit of their information is how simple they make it to compare companies internationally. As experts in company information, they can help you to monitor your global operations and comply with country by country (CbyC) reporting. Equip yourself for these challenges by using Bureau van Dijk’s TP Catalyst, a tool that simplifies the process of identifying comparables and produces the required analyses for transfer pricing reporting. Welcome to the business of certainty.

Website www.analysisgroup.com

16To register or for the latest information, please visit: finance.knect365.com/tp-minds-americas-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected]

A world leading provider of audit, tax and consulting services to entrepreneurial growth-focused organisations and multinationals globally. As an integrated team, we share skills, insight and resources, as well as a client-centric approach that’s based on a deep understanding of your business. Our global transfer pricing experts work together with you to understand your business and your requirements. This is The Power of Being Understood.• We are the 7th largest global audit, tax and consulting network• We have firms in over 110 countries • We have combined staff of over 37,500 in over 730 offices across the Americas, Europe, MENA, Africa and Asia Pacific.

Website www.rsm.global

Alder & Sound is thrilled to present its new little sister Aibidia. Although the heart of Aibidia is pure gold, we have to admit that like little sisters often do, also Aibidia can sometimes be very disruptive. Aibidia is determined to follow her dreams – to redefine the traditional transfer pricing industry. She says it is possible by combining her big brother’s in-depth legal and economic expertise with her capabilities in data & analytics and artificial intelligence. She is also very agile and tends to be always way ahead of the others. Learn more about Aibidia and follow her journey at www.aibidia.com.

Website www.aibidia.com.

ASSOCIATE PARTNERS

At S&P Global Market Intelligence, we know that not all information is important—some of it is vital. We integrate financial and industry data, research and news into tools that help track performance, generate alpha, identify investment ideas, understand competitive and industry dynamics, perform valuation, and assess credit risk. Investment professionals, government agencies, corporations, and universities globally can gain the intelligence essential to making business and financial decisions with conviction.

S&P Global Market Intelligence is a division of S&P Global (NYSE: SPGI), which provides essential intelligence for individuals, companies, and governments to make decisions with confidence. For more information, visit www.spglobal.com/marketintelligence.

Website www.spglobal.com/marketintelligence

RoyaltyRange is a transfer pricing database provider with three professional databases, covering royalty rates, loan interest rates and service fees.

Our third-party comparables data is used for a number of purposes, including transfer pricing, financial transaction benchmarking, royalty rates and service fees benchmarking, valuation of intangibles, and purchase price allocations.

Accessing high-quality third-party data is crucial for determining arm’s length conditions for intercompany transactions. Multinational enterprises, global consulting companies, international law firms and government authorities in more than 60 countries use our databases to access data quickly and easily.

Website www.royaltyrange.com

Loyens & Loeff has an experienced transfer pricing team that provides transfer pricing related advice in the Netherlands, Belgium, Luxembourg and Switzerland. As transfer pricing is intertwined with most tax issues, we fully integrate transfer pricing expertise with our various tax and legal practices. The team consists of experts in corporate income tax, value added tax, customs duties, commercial contracts, controversies, litigation and state aid procedures. With this expertise we assist clients in planning, documentation, tax audits, negotiations with (international) tax authorities in uni-, bi- and multilateral APAs, litigation and state aid procedures.

Website www.loyensloeff.com

Cuatrecasa’s Tax Practice has a transfer pricing group made up of over 50 lawyers, including 10 partners, specialized in this matter, with solid experience in advising on all types of transactions in this specialty (e.g., business restructuring, distribution agreements, service and management fees, financial transactions and products, royalties and IP management). We advise clients from many jurisdictions and sectors, including finance, private equity, oil and gas, utilities, infrastructure, automotive, life science, software and IT, consumer goods, real estate, entertainment, start-ups and family office. The transfer pricing group’s broad knowledge of the subject ensures high value-added integrated services at the planning stage of related party transactions, through business restructuring designing, negotiating advance pricing arrangements with the Tax Authorities or through benchmarking of related party transactions; at the stage of the mandatory documentation for related party transactions; and at later stages, advising and representing during tax audit and in the courts, and assisting in mutual agreement procedures to avoid double taxation.

To provide these services, the lawyers in the transfer pricing group have an in-depth, cutting-edge knowledge of the regulations and case law, as well as of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, and of the reports published by the European Union Joint Transfer Pricing Forum.

Website www.cuatrecasas.com

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