Executive Program in Transfer Pricing Program content - Draft program: Subject to changes - Unil
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Executive Program in Transfer Pricing
Program content – Draft program: Subject to
changes
B – Basic level course / I – Intermediate level course / A – Advanced level course
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:FEBRUARY 2021 (Online course)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 18th – Introduction to Transfer Pricing (TP), BEPS & Digitalization
Online course
Lecturer Detailed program
Time
08:50 – 09:00 Opening of the program and welcome address
Prof. Dr. Robert o Profit allocation in an MNE
Danon (Program o The role and importance of ALP (Transfer Pricing)
Director, Switzerland) & o State Aid and ALP
09:00 – 09:15 Prof. Dr. Vikram o Pillar I and Formulary approaches towards profit allocation in the
Chand Digitalized Economy
(Program Director,
Switzerland)
Prof. Dr. Guglielmo o Profit allocation using the ALP: Article 9 and 7 of the OECD, UN
09:15 – 10:30 Maisto and US Models
(Partner, Maisto e
Associati, Italy)
Dr. Richard Collier
(Former Senior Advisor,
11:00 – 12:30 o Profit allocation in an MNE: Past, Present and Future
OECD / Associate Fellow,
University of Oxford, UK)
14:00 – 15:30 Dr. Richard Collier o Profit allocation in an MNE: Past, Present and Future
Mr. Matt Andrew
(Head of Tax Treaty, o The OECDs ongoing work on Digitalization: The unified approach
16:00 – 17:00 Transfer Pricing &
Financial Transactions
Division, OECD, France)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Friday 19th – Functional and value chain analysis for different business models
Online course
Lecturer Detailed program
Time
o Different multinationals business models
o Discussion of different kind of Functions, Assets and Risks in
multinational setup
o Characterization of manufacturing, distribution and services
Mr. Rachit Agarwal entities
09:00 – 10:30 (Transfer Pricing Director, o Theoretical framework: Chapter 1 of the OECD Guidelines and
11:00 – 12:30 DLA Piper, UK) & its comparison with the US and UN Transfer Pricing guidelines
14:00 – 16:00 Mrs. Vicki Bales o The accurate delineation of the actual transaction
(Transfer Pricing Director, o Role of contracts and agreements
DLA Piper, UK)
o Allocations of Functions, Assets and Risks in a TP set up
(B, I)
o Control over risk and financial capacity to bear risks
o Non recognition of transactions
o Value chain, Value shop and Value network analysis in a
Multinational Enterprise: Selected case studies
o Value chain analysis: An example from the Fast Moving
Mr. Vineet Rachh Consumer Goods sector – Household consumer products
16:30 – 18:00 (Senior Director, Procter &
Gamble, Singapore) (A)
(P&Gs centralized and decentralized business models)
Saturday 20th - Transfer Pricing methods with a focus on the profit split method
Online course
Lecturer Detailed program
Time
o Theoretical framework: Chapter 2 of the OECD Guidelines and
its comparison with the US and UN Transfer Pricing guidelines
o TP methods:
Mr. Paolo Valerio - Comparable uncontrolled price method (CUP)
09:00 – 10:30
Barbantini - Resale Price method (RPM)
11:00 – 12:30
(Deputy Director General, - Cost plus method (CPM)
14:00 – 16:00
Italian Revenue (Agenzia delle - Transactional net margin method (TNMM)
16:30 – 18:00 entrate), Italy) - Profit split method (PSM) (including recent developments)
(I, A) - Other methods including the sixth method for commodities
- Valuation techniques for intangibles
o Applying the TP methods in practical cases – Policy makers
perspective
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:MARCH 2021 (Online course)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 18th – Financial Accounting : Standalone and Consolidated Statements
Online course
Lecturer Detailed program
Time
o Overview of IFRS/US GAAP
o Stand-alone vs consolidated financial statements of an MNE
o Profit and loss account, balance sheet and cash flow statement
Mr. Koen De o Relationship between accounting and tax law
09:00 – 10:30 Grave o Relationship between management accounting and transfer pricing
11:00 – 12:30 ( Managing
o Principles of tax accounting
Director Tax
14:00 – 16:00 o Accounting for uncertain tax and transfer pricing positions
Accounting
16:30 – 18:00 Services, PWC o Financial statements and TP
Belgium) o Practical case study : Significant differences between IFRS and local
(B, I) GAAP, Change of ownership and write offs – What goes in P & L to
calculate operating income – TP adjustments
o Pillar I: Using consolidated financial statements to determine the
Pillar I tax base
o Determining consolidated income and expenses of an MNEs business
line – Selected examples
Friday 19th - Comparability and economic analysis with a focus on intercompany transactions with
goods
Online course
Lecturer Detailed program
Time
o Theoretical framework: Chapter 3 of the OECD Guidelines and its
comparison with the US and UN Transfer Pricing guidelines
o Business models to buy, make and sell goods
o The accurate delineation and recognition of the actual transaction
09:00 – 10:30 Mr. Gerhard o Comparability analysis
11:00 – 12:30 Foth - List of databases for carrying out the search process
(Director, KPMG,
14:00 – 16:00 Switzerland)
- The comparable search process
16:30 – 18:00 (I, A) - Comparability adjustments in practice
- Automation in the comparability search process
- Case studies to demonstrate benchmarking of manufacturing and
distribution models
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Saturday 20th – Intra group services transactions and cost contribution arrangements
Online course
Lecturer Detailed program
Time
o Theoretical framework: Chapter 7 and Chapter 8 of the OECD
Guidelines and its comparison with the US and UN Transfer Pricing
guidelines
o Types of Intra group services: Non chargeable services, high Value
Mr. Mukesh added services, low value added services etc
09:00 – 10:30 Butani o The accurate delineation and recognition of the actual transaction
11:00 – 12:30 (Managing o Direct charging vs indirect charging and use of allocation keys
14:00 – 16:00 Partner, BMR o TP methods for services
Legal, India) o Comparability issues and adjustments
(I, A) o Cost contribution agreement’s (CCA) and the use of such agreements
for intra group services
o Case studies to demonstrate benchmarking intragroup services using
selected databases
Dr. Marta
Pankiv o Industry perspective : Best practices for defending intra group
16:30 – 18:00
(Director of Tax, services audits – High and low value added services
Tricentis, Austria)
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:APRIL 2021 (Online course)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 15th - Intra group intangible transactions and cost contribution arrangements
Online course
Lecturer Detailed program
Time
A journey through the IP lifecycle:
o Theoretical framework on intragroup intangibles transactions:
Chapter 6 and Chapter 8 of the OECD Guidelines and its
comparison with the US and UN Transfer Pricing guidelines
o Definition of IP for TP purposes
Mrs. Isabel o Developing and Structuring IP
09:00 – 10:30 Verlinden o Ownership and intangible related return issues
(Global Head Transfer
11:00 – 12:30 o Types of IP transactions within a MNE group: Licensing vs sales vs
Pricing Services, PWC
14:00 – 16:00 Belgium) franchising
(I, A) o TP methods for intangibles
o Valuation techniques of IP: income based approach, market
based approach, game (bargaining) theory and others
o Hard to value intangibles
o Benchmarking IP transactions using selected databases with a
focus on the PSM
o Digital Economy and IP
Mr. Giuseppe
Abatista
(Group Tax, Pricing, o Industry perspective: Best practices for defending intangible
16:30 – 18:00 Planning & Control
Director, Salvatore
transactions tax audits
Ferragamo, Italy)
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Friday 16th - Intra group financing transactions
Online course
Lecturer Detailed program
Time
o Theoretical framework on intragroup financing transactions:
Chapter 10 of the OECD Guidelines and its comparison with the US
and UN Transfer Pricing guidelines
o Overview of treasury functions
o The accurate delineation and recognition of the actual transaction
Mrs. Amanda o Credit ratings
09:00 – 10:30 Pletz o Inter-company loans
11:00 – 12:30 (Associate Director, o Intercompany guarantees
14:00 – 16:00 NERA Economic o Cash pooling
Consulting, UK) o Derivatives and Factoring
(I, A) o Foreign exchange (FX) risk management
o Captive insurance
o BEPS and intra group finance issues
o Recent work of OECD WP 6 on financial transactions
o Benchmarking financial transactions using selected databases with
a focus on the PSM
Mrs. Emanuela o Industry perspective: Best practices for defending financing
Buono transactions tax audits
(Head of Tax Planning
and Monitoring, Enel
16:30 – 18:00 Green Power, Italy) &
Mrs. Stefania
Cilurzo
(Head of Transfer
Pricing, Enel Spa, Italy)
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Saturday 17th - Attribution of profits to a Permanent Establishment (PE)
Online course
Lecturer Detailed program
Time
Prof. Dr. Xaver Ditz
(Partner, Flick Gocke
09:00 – 10:30 Schaumburg, Germany)
o Attribution of profits to a PE: German Perspective
(A)
o Basis for profit attribution: Article 7 Of OECD MC and UN Model
and commentaries
o Authorized OECD Approach and its comparison with other
Mr. Stefaan De approaches
11:00 – 12:30 Baets o The TP methods to attribute profits
14:00 – 16:00 (Senior Counsel TP, PWC
o BEPS and PE’s – Extended PE definition and additional guidance on
16:30 – 18:00 Belgium)
(I, A) BEPS Action 7
o Special considerations for purchasing operations
o Special consideration for distribution models
o Special consideration for digital businesses
o Application of the ALP to digitalized businesses
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:MAY 2021 (Online course)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 6th - Business Restructuring
Online course
Lecturer Detailed program
Time
o Theoretical framework and types of business restructuring
Chapter 9 of the TP OECD Guidelines
Mr. Xavier o Applying the ALP for the restructuring and remuneration of post-
09:00 – 10:30
Eggspuhler restructuring transactions
11:00 – 12:30
(Partner, Ernst & o The accurate delineation and recognition of the actual transaction
14:00 – 16:00 Young, Switzerland) o Location savings and market premium
(I, A) o PE issues and business restructurings
o Case studies on pre and post restructurings scenarios
o Best practices for defending business restructuring audits
Mrs. Cansu o The role of TP in Mergers and Acquisitions
Bagran Ilhan o TP in tax due diligence
16:30 – 18:00 (Global Head of M&A o Deal structuring
Tax, ABB, Switzerland) o TP in post deal integration and key pressure points
(A) o Case studies
Friday 7th - Transfer Pricing and indirect Taxes
Online course
Time Lecturer Detailed program
Mr. Massimo Fabio o Theoretical framework and basic concepts in transfer pricing and
(Partner, KPMG Italy customs
09:00 - 10:15
Head of Trade & o World Trade Organization (WTO) Customs valuation and European
10:30 – 12:00 Customs Services) Union (EU) Customs valuations rules and their interaction with TP
(I, A) rules
o Case studies
Mr. Stéphane o Valuation under EU Value Added Tax (VAT) rules and OECD VAT
Buydens rules and TP rules
13:00 – 14:30 (VAT Policy Advisor, o The coordinated / uncoordinated approach with OECD Transfer
15:00 – 16:45 OECD, France) Pricing rules
(I, A) o Administrative issues
o Case studies
Mrs. Nadia
Bouzenzana
(Senior Director o Diversified MNE Businesses
International Trade &
17:00 – 18:00 o Industry perspective : Best practices for defending indirect tax and
Government Incentives,
Honeywell Technology, TP audits
Switzerland)
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Saturday 8th - Transfer Pricing Management within MNEs
Online course
Lecturer Detailed program
Time
o Transfer pricing risk management
o Country by country reporting (Action 13 of the BEPS Plan)
o Best practices for documentation (Master file, Local file)
Mrs. Olivia Gedge o Other transfer pricing compliance
09:00 – 10:30
(Director Global Transfer o Managing global TP documentation
11:00 – 12:30
Pricing Services, o Setting up and implementing an intra group TP policy
14:00 – 16:00 KPMG, Switzerland) o Managing transfer pricing policy - Best practices
(I, A) o ERP Systems and operational transfer pricing
o Technology enablement and automation
o TP in the board room and media
o Case studies
Dr. Lluis M. Fargas
Mas o Managing TP within a MNE
(Vice President Finance & o Setting up a TP policy
16:30 – 18:00 Tax, Europe & Asia
Pacific, Howmet
o Implementing TP control framework
Aerospace, Switzerland) o CBC, Master File and local file
(I, A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:JUNE 2021 (Online course)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 3rd - Preventing and resolving TP disputes
Online course
Lecturer Detailed program
Time
o Theoretical framework and definitions:
- Advance Pricing Agreement (APA)
Dr. Renato Salerno - Safe Harbours
(Senior Economist
Responsible for TP,
- Domestic litigation
State Secretariat for - Mutual Agreement Procedures (MAP)
09:00 – 10:30 International Financial - Arbitration (conventional or baseball arbitration)
11:00 – 12:30 Matters, Switzerland / - Arbitration within the EU
14:00 – 16:00 Italy) & Case Studies from taxpayer perspective
Mr. Aurelio o Negotiations of APA’s, MAP’s
Massimiano o Issues and best practices in negotiations
(Partner, Maisto e
Associati, Italy)
o Case Studies from tax authorities perspective
(I, A)
Mr. Fabio De
Angelis
(Senior Director, Global
16:30 – 18:00 Taxes, eBay
o In house perspective on managing disputes
International
Management B.V., The
Netherlands/ Italy)
(I, A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Friday 4th - Emerging audit issues in selected countries
Online course
Lecturer Detailed program
Time
Mr. Alexander Haller
(Director, WTS Germany) o Germany:
09:00 – 10:30 & - Overview of TP Law
Mrs. Melanie - TP documentation
Appuhn-Schneider - Trends in audits / disputes
(Director, WTS Germany)
(A)
Mrs. Gabriella o Italy:
Cappelleri - Overview of TP Law
10:45 – 12:15 (Of Counsel, Maisto e - TP documentation
Associati, Italy) - Trends in audits / disputes
(A)
o France:
Mr Bruno Gibert - Overview of TP Law
13:45 – 15:15 (Partner, CMS Francis
Lefebvre Avocats, France)
- TP documentation
(A) - Trends in audits / disputes
Mrs. Olivia Gedge &
Dr. Natassia
o Switzerland:
Burkhalter-Martinez
(Head of section, Federal
- Overview of TP Law
15:45 – 17:15 Department of Finance for - TP documentation
Federal Tax - Trends in audits / disputes
Administration,
Switzerland)
(A)
Mr. Joel Cooper
(Partner, Ernst & Young, o Structuring MNE Business Models with controversy preparedness in
17.30-18.30 UK) mind
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Saturday 5th – Disputes in the EU : State Aid and APA’s
Online course
Lecturer Detailed program
Time
Mr. Mario Tenore
(Associate, Maisto e o The ALP and fundamental freedoms
Associati, Italy)
o State Aid & APA’s
09:00 – 10:30 (I, A) o The case law of the ECJ (eg. Apple, Amazon, Starbuck and Fiat
11:00 – 12:30 Finance)
o Case studies
Saturday 5th - Emerging audit issues in selected countries
Online course
Lecturer Detailed program
Time
Dr. Niraja Srinivasan
(Partner, Nera Economic o US
Consulting / Lecturer,
14:00 – 15:30 - TP documentation
Texas A&M / Former VP
Global Tax, Transfer - Trends in audits / disputes
Pricing, Dell, USA)
(A)
Mr. Sam Sim o Asia Pacific
(Co-founder, Senior of - Overview of TP of selected countries
16:00 – 17:30 Counsel, WTS Taxise, - TP documentation
Singapore) - Trends in audits / disputes
(A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:JULY 2021
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Thursday 1st - Pillar I and Pillar II of the OECDs project on Digitalization
Room: Geopolis 1612
Lecturer Detailed program
Time
Prof. Dr. Robert
Danon &
Prof. Dr. Vikram
Chand &
Mr. Tim McDonald o Pillar I: The Unified Approach: A detailed analysis
(Vice President Global - Amount A
Taxes, Procter & - Amount B
Gamble, USA) – - Amount C
09:00 – 10:30 Tentative & - Case Studies on Pillar I
11:00 – 12:30 Mr. Jean-Louis o Pillar II
14:00 – 15:00 Geyr - Income inclusion rule
(Senior Vice President,
- Base eroding payments rule
Group Head of Global
Tax, Nestlé, Switzerland) - Switch Over clauses
– Tentative & - Subject to tax clauses
Mr. Manuel De los - Case Studies on Pillar II
Santos Poveda
(Advisor-CTPA, OECD,
France)
(I, A)
Mr. Elias Thomas o Online Streaming Business:
(Tax Director – Transfer o bValue creation, TP Management issues and experiences
Pricing, Spotify, Sweden)
15:00 – 16:00 o The use of CUP, TNMM and PSM on selected transactions
(A) o Impact of Pillar I and Pillar II
16:00 Boat trip
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Friday 2nd - TP in selected industries
Geopolis 1612
Lecturer Detailed program
Time
o Commodity trading businesses
Mrs. Olivia Gedge
09:00 – 10:30 o Value creation, TP Management issues and experiences
(A)
o The use of the sixth method
Mr. Andreas Risi o Commercial Banking business
(Head of Tax
o Value creation, TP Management issues and experiences
Switzerland, UBS) &
11:00 – 12:30 o The use of CUP, TNMM and PSM on selected transactions
Mr. Roland Britt
(Director Group Tax,
o Impact of Pillar I and Pillar II
UBS, Switzerland) (A)
Mr. Thomas Hug o Private Banking business
(Executive Director,
o Value creation, TP Management issues and experiences
14:00 – 15:30 Group Tax & TP, Bank
Julius Baer, Switzerland) o The use of CUP, TNMM and PSM on selected transactions
(A) o Impact of Pillar I and Pillar II
Mrs. Andrea o Reinsurance business
Grainger o Value creation, TP Management issues and experiences
(Global Head of Transfer o The use of CUP, TNMM and PSM on selected transactions
16:00 – 17:30 Pricing, Swiss Re
o Impact of Pillar I and Pillar II
Management,
Switzerland) (A)
Graduation of the 2019’ and 2020’ batch
17:30 Graduation of the 2019’ and 2020’ batch following by a dinner apéro
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Saturday 3rd - TP in selected industries
Room: Geopolis 1612
Lecturer Detailed program
Time
Mr. Philippe o Pharma businesses
Paumier o Value creation, TP Management issues and experiences
09:00 – 10:30 (Founder, Vector TP,
France)
o The use of CUP, TNMM and PSM on selected transactions
(A) o Impact of Pillar I and Pillar II
Mr. Massimo Di o Luxury goods businesses
Cesare o Value creation, TP Management issues and experiences
11:00 – 12:30 (Group Head of Tax, o The use of CUP, TNMM and PSM on selected transactions
Richemont, Switzerland) o Impact of Pillar I and Pillar II
(A)
Mr. Yvan Mollier o FMCG businesses
(Global Indirect Tax o Value creation, TP Management issues and experiences
14:00 – 15:30 Director, General Mills
o The use of CUP, TNMM and PSM on selected transactions
International,
Switzerland) (A)
o Impact of Pillar I and Pillar II
Mr. Tim Mathey
(Director European Tax, o Online Gaming Businesses
Electronic Arts,
o Value creation, TP Management issues and experiences
Switzerland) &
o The use of CUP, TNMM and PSM on selected transactions
16:00 – 17:30 Mr. Xavier Camps
(Tax Senior Manager,
o Impact of Pillar I and Pillar II
Electronic Arts,
Switzerland) (A)
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:Technical paper
Thesis Total Points Points to pass
Total of points 100 68
Thesis deadlines
Thesis topic selection June 01
Thesis Outline August 15
1st Draft September 30
Final Draft October 31
Please note that the final draft has to be sent by e-mail in a word format (Transferpricing@unil.ch)
The print out of this has to be sent by post at the following address:
Centre de droit public
University of Lausanne
Madame Natacha Fauconnier
Extranef Building - Office 124
CH-1015 Lausanne
© 2021 Executive Program in Transfer Pricing. All rights reserved.
The EPTP is kindly sponsored by:You can also read
