Advanced Transfer Pricing Course General Topics

WU Campus © Studio Huger

Advanced Transfer Pricing Course General Topics

Content Course Overview

1

Content and Structure

2

Lecturers4 General Information

6

Target Group

6

Course Level and Prerequisites

6

Venue7 Course Fee

7

Course Materials

7

Registration7 Contact7 Vienna Certificate in Transfer Pricing

8

Application Form

9

WU Campus © Johannes Zinner

Course Overview The increasing global trade and the role of multinational enterprises in the global economy have boosted the relevance of transfer pricing topics. The number of countries having transfer pricing legislation in place has increased from a mere four in 1994 to more than 80 in 2014. Therefore, transfer pricing is one of the most relevant and challenging topics in the international tax environment. The Advanced Transfer Pricing Course (General Topics) offered by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law meets the increasing demands for education in this field by offering high quality training. With renowned experts from all over the world as lecturers, training at the highest international level with a great degree of practical relevance is guaranteed. The Institute for Austrian and International Tax Law (www.wu.ac.at/en/taxlaw), part of WU (Vienna University of Economics and Business), is among the largest academic institutions in the world carrying out research and teaching about tax law. Its main fields of activities are corporate tax law, international tax law, and European tax law. Staff also participate in numerous national and international tax projects and have developed an impressive network with contacts to over 90 countries over the years. The Institute's staff currently comprises of 60 academic staff members, 18 administrative staff members as well as many visiting professors and guest researchers from around the world. The WU Transfer Pricing Center (www.wu.ac.at/taxlaw/institute/wutpc) at the Institute for Austrian and International Tax Law aims at researching, analysing, debating, and teaching transfer pricing topics. Through its activities, it positions itself as a global institution providing the missing nexus between theory and practice in approaching transfer pricing topics. The center combines both the academic and practical perspectives and its approach is highly international and interdisciplinary.

1

WU Library © WU

Content and Structure Monday, May 29, 2017 Introduction to Transfer Pricing; Transfer Pricing and Attribution of Profits to Permanent Establishments 09.00-10.30 Introduction to Transfer Pricing Raffaele Petruzzi and Claire Peng 11.00-12.30 Functional Analysis and Value Chain Analysis Alfred Storck and Raffaele Petruzzi 14.00-15.30 Transfer Pricing and Attribution of Profits to Permanent Establishments Hans Pijl 16.00-17.30 Workshop: Practical Application of Transfer Pricing and Attribution of Profits to Permanent Establishments Hans Pijl

Tuesday, May 30, 2017 Transfer Pricing Methods 09.00-10.30 Introduction to Transfer Pricing Methods and Their Selections Most appropriate method vs. best method; use of more than one method; benchmarking Traditional Transaction Methods Comparable uncontrolled price method; resale price method; cost plus method Axel Eigelshoven 11.00-12.30 Workshop: Practical Application of the Transfer Pricing Methods (First Part) Axel Eigelshoven 14.00-15.30 Transactional Profit Methods Transactional net margin method; transactional profit split method Other Methods Safe-harbours; sixth-method; use of financial valuations Sebastien Gonnet and Romero Tavares 16.00-17.30 Workshop: Practical Application of the Transfer Pricing Methods (Second Part) Sebastien Gonnet and Romero Tavares

2

Wednesday, May 31, 2017 Administrative Approaches to Avoiding/Minimizing and Resolving Transfer Pricing Disputes 09.00-10.30 Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes Rulings and Advanced Pricing Agreements (APAs); safe harbours; simultaneous tax examinations Giammarco Cottani 11.00-12.30 Workshop: Practical Application of the Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes Giammarco Cottani 14.00-15.30 Administrative Approaches to Resolving Transfer Pricing Disputes Mutual Agreement Procedures (MAPs); arbitration (conventional, baseball, EU arbitration) Monique van Herksen 16.00-17.30 Workshop: Practical Application of the Administrative Approaches to Resolving Transfer Pricing Disputes Monique van Herksen

Thursday, June 1, 2017 Transfer Pricing Risk Management and Compliance; Transfer Pricing in Specific Geographic Areas 09.00-10.30 Transfer Pricing Risk Management and Compliance Transfer pricing risk management; transfer pricing documentation (master file, local file, country-by-country report) Sven Bremer 11.00-12.30 Workshop: Practical Application of Transfer Pricing Risk Management and Compliance Sven Bremer 14.00-15.30 Transfer Pricing in Specific Geographic Areas (First Part) Transfer pricing at the OECD (including current BEPS projects) Melinda Brown 16.00-17.30 Transfer Pricing in Specific Geographic Areas (Second Part) Transfer pricing in developing countries (including updated UN Manual) Melinda Brown

Friday, June 2, 2017 Transfer Pricing Aspects of Selected Intra-Group Transactions 09.00-10.30 Transfer Pricing and Intra-Group Services Alfred Storck and Claire Peng 11.00-12.30 Transfer Pricing and Intangibles Alfred Storck 14.00-15.30 Transfer Pricing and Intra-Group Financing Raffaele Petruzzi

3

Lecturers Lecturers are international leading transfer pricing experts from academia, international organizations, government officials, the business community, and advisory firms.

Prof. Dr. Alfred Storck (Switzerland/Austria) Professor of Transfer Pricing and International Taxation Managing Director, WU Transfer Pricing Center Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business), Vienna (Austria)

Dr. Raffaele Petruzzi, LL.M. (Italy/Austria) Managing Director, WU Transfer Pricing Center Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business), Vienna (Austria) Transfer Pricing Advisor Deloitte, Vienna (Austria)

Claire (Xue) Peng, LL.M. (China/Austria) Research and Teaching Associate, WU Transfer Pricing Center Institute for Austrian and International Tax Law WU (Vienna University of Economics and Business), Vienna (Austria)

Dr. Sven Bremer (Germany) Global Head of Group Transfer Pricing Siemens, Munich (Germany)

Melinda Brown (Australia/France) Senior Transfer Pricing Advisor Centre for Tax Policy and Administration OECD, Paris (France) Member of the UN Subcommittee on Transfer Pricing United Nations, New York (United States)

4

Dr. Giammarco Cottani, LL.M. (Italy) Head of Transfer Pricing Ludovici Piccone & Partners, Rome and Milan (Italy)

Axel Eigelshoven (Germany) Certified Tax Advisor and Transfer Pricing Partner PwC, Düsseldorf (Germany)

Sébastien Gonnet (France) Vice President NERA Economic Consulting, Paris (France)

Monique van Herksen (The Netherlands/United States) Independent Tax Consultant Member of the UN Subcommittee on Transfer Pricing United Nations, New York (United States)

Hans Pijl, LL.M. (The Netherlands) Former Partner on International Taxation Andersen and Deloitte, Amsterdam (The Netherlands) Part-Time Judge The Hague Tax Court of Appeals, The Hague (The Netherlands)

Romero J.S. Tavares, Esq., LL.B., M.B.A. (Austria/Brazil/United States) International Tax Policy Advisor The World Bank Group

5

General Information The course lasts 5 days and is held from May 29 to June 2, 2017. The course is entirely held in English. In order to guarantee a high degree of interactivity, the course is strictly limited to a maximum of 30 participants. Demand for the course generally is high and an early registration recommended. The course is structured into four sessions per day of 1.5 hours each. Each topic is analyzed with a mix of theory and workshops (with case studies).

Target Group The course is targeted at professionals around the world who want to build or broaden their knowledge of transfer pricing. Participants are typically tax and transfer pricing advisors (accountants, economists, and lawyers), in-house tax and finance employees of international companies, government officials, and academics.

Course Level and Prerequisites The course starts at an introductory level. Hence, it can be attended by both participants with no experience in transfer pricing and participants with some experience in the field. No advanced preparation is required.

Participants from previous editions of our course are from 36 different countries

6

Venue The course is held in Vienna at the WU campus (www.wu.ac.at/campus/en), which is conveniently accessible by public transportation. The address of the campus is: WU (Vienna University of Economics and Business) Welthandelsplatz 1 1020 Vienna, Austria

Course Fee The course fee is EUR 2,250. A 20% “early bird discount” is applicable to applications sent by January 23, 2017. The course fee covers course participation, all course materials, lunches, coffee breaks and refreshments. Costs of travel and accommodation are not covered. A dinner is organized for the evening of May 31, 2017.

Course Materials The participants will receive a binder containing the presentations and the case studies discussed during the workshops at the beginning of the course. Additionally, a USB stick containing further documents relevant for the course will be provided.

Registration Please fill out the attached application form and submit it to Christina Sudrat (christina.sudrat@ wu.ac.at).

Payment You will receive an invoice for the participation fee of EUR 2,250 (or of EUR 1,800 in case of application of the “early bird discount”). We kindly ask you to transfer your payment within three weeks of the date of the invoice.

Cancellation Any notification of cancellation of registration must be sent in writing. In case of cancellation before April 29, 2017, the participation fee will be refunded. No refund can be made for cancellations received after April 29, 2017.

Contact WU Transfer Pricing Center Institute for Austrian and International Tax law WU (Vienna University of Economics and Business) Welthandelsplatz 1, Building D3, 1020 Vienna, Austria E-mail: [email protected] Website: www.wu.ac.at/taxlaw/institute/wutpc

7

Participants Course 2016

Vienna Certificate in Transfer Pricing This course is part of the Vienna Certificate in Transfer Pricing. The Vienna Certificate in Transfer Pricing is a certificate program which offers a unique opportunity to combine two excellent courses with a high-class case study as well as a technical paper supervised by the Managing Directors of the WU Transfer Pricing Center. Ideally, all four parts should be taken within one year. Previously completed courses can also be transferred to the certificate program. The certificate is targeted at professionals around the world who want to build or broaden their knowledge in transfer pricing. Participants are typically tax and transfer pricing advisors (accountants, economists, and lawyers), in-house tax and finance employees of international companies, government officials, and academics. The candidate will receive the “Vienna Certificate in Transfer Pricing” upon successful completion of the following four parts: 1. Advanced Transfer Pricing Course (General Topics) This five-day course consists of an introduction to transfer pricing followed by lectures and workshops on the attribution of profits to permanent establishments, transfer pricing methods, administrative approaches to minimizing and resolving transfer pricing disputes, as well as transfer pricing risk management and compliance, among others. 2. Advanced Transfer Pricing Course (Specific Topics) This five-day course deals with detailed lectures and intensive workshops on specific transfer pricing topics, such as transfer pricing and services, financing, intangibles, supply chain management and business restructurings, as well as indirect taxes and customs. Lecturers from both courses are internationally renowned transfer pricing experts from academia, international organizations, the business community, government officials, and advisory firms. 3. Case Study A case study should be solved by the candidate. This case study will be provided and supervised by the Managing Directors of the WU Transfer Pricing Center. 4. Paper A paper, in the form of a technical article (3,000-5,000 words), should be prepared by the candidate in English. The topic of this paper will be agreed by the candidate together with the Managing Directors of the WU Transfer Pricing Center, who will supervise said article. The fee to access the entire certified program amounts to EUR 8,250.00. Previously completed courses can be deducted from this amount and early bird discounts applied. For further information, please contact us on [email protected].

8

Application Form I hereby submit my application for the Advanced Transfer Pricing Course (General Topics) held from May 29 to June 2, 2017 in Vienna (Austria).

Please write clearly using block letters. All fields marked with * are required.

First name* Surname* Academic Title (e.g. BA, MA, LL.M., Dr.) Gender

male

□

female

□

Nationality* Current position and company / organisation*

Private details Street Zip-Code, City Country Phone / Mobile* (for very urgent issues) E-Mail*

Billing address Please indicate the exact name and address to be shown on the invoice Name / company* Street* Zip-Code, City* Country* Tax code / Reference

Date, Signature

9

WU (Vienna University of Economics and Business) Welthandelsplatz 1, 1020 Vienna, Austria wu.ac.at