11th Annual IBA Finance & Capital Markets Tax Virtual Conference
17 Jan - 4 Mar 2022
Session information
Transfer pricing: anticipating and responding to new challenges
Thursday 3 March (1415 - 1530)
Description
- The key points and trends in transfer pricing litigation, including Italian Supreme Court case no 1232 (January 21 2021), Coca-Cola v IRS (November 18 2020), among others;
- New developments in applying transfer pricing rules to financial transactions;
- How tax authorities’ transfer pricing audits are evolving for hidden permanent establishments, forward subscription structures and other cases;
- The changing role of profit split methods in resolving transfer pricing disputes;
- Update on the mutual agreement procedure (MAP) and advance pricing agreement (APA) procedures; and
- Practical issues and the impact of Covid-19 on transfer pricing and year-end adjustments.
Session / Workshop Chair(s)
| Richard Slowinski | Alston & Bird, Washington, District of Columbia, USA |
Speakers
| Rezan Okten | Houthoff, Amsterdam, Netherlands |
| Raul-Angelo Papotti | Chiomenti Studio Legale, Milan, Italy; Scholarship Officer, Taxes Committee |
| Clifford Rand | Aird & Berlis, Toronto, Ontario, Canada |
| Fernando Tonanni | Machado Meyer Advogados, São Paulo, Brazil; Young Lawyers Programme Officer, Taxes Committee |
| Philip Tully | Matheson, Dublin, Ireland |
| Monique van Herksen | Simmons & Simmons, Amsterdam, Netherlands |