Session details

6th Annual IBA Tax Conference

30 Jan - 31 Jan 2017


Session information

Transfer pricing


European Regional Forum (Lead)
Taxation Section (Lead)


• BEPS and transfer pricing units • Arm’s length principal revisited • Guidance on profit splits • Documentation requirements for financial interest rates and financial contribution • Risk/recharacterisation/capital arrangement • State aid • Establishment of appropriate fees for guarantees and keep well • Chevron case • Experience with mutual agreement procedures regarding adjustment of interest rates and financial conditions • Collective investment vehicles – do they meet European tax exemptions?


Henry Birnkrant Alston & Bird LLP, Washington, District of Columbia, USA
Pascal Hinny Lenz & Staehelin, Zürich, Switzerland