Transfer Pricing and International Tax Forum 2015 - Akolade

E H E VE T RIC SA O FF D P 40 A R $4 N D A ST

3rd Annual

Transfer Pricing and International Tax Forum 2015 Enhancing cross border related party transactions

13 - 15 MAY 2015 RADISSON BLU SYDNEY

GOVERNMENT KEYNOTE: •

David Pengilley, General Manager, Office of the Inspector-General of Taxation

12 CPD HOURS AVAILABLE *See inside for details

INTERNATIONAL KEYNOTE: • •

Ningyue Wang, Regional Head of Transfer Pricing, Intel Corporation, Hong Kong Jean-Louis Barsac, Group Head of Transfer Pricing, Alcatel-Lucent, China

SPEAKER LINE-UP: • • • • • • • • • • • • • • • •

KEY BENEFITS OF ATTENDING • •

Craig Cavanagh, Tax Director, AECOM Joe Hedges, Manager, Taxation, Group Tax, Qantas Airways Limited Patrick Thompson, Head of Asian Transfer Pricing, Morgan Stanley Jeremy Child, Head of Tax, Australia, RBS Kelly Richmond, Transfer Pricing Adviser, RBS Harry Bernfield, Regional Taxation Manager, Asia Pacific, Brambles Paul Suppree, Assistant Director, Corporate Tax Association Darren Baxter, International Tax and Treasury Manager, Billabong Group Nick Followes, Group Taxation Manager, SunRice Peter Adams, Spokesperson, Taxpayers Australian

• • •

Gain practical approaches to deal with the high cost of compliance Understand and implement the OECD BEPS within your organisation Strengthen your international corporate tax reporting systems Incorporate effective transfer pricing risk management and mitigation tools Learn strategies to handle transfer pricing audits

Peter Anthonsen, General Manager Tax, Tabcorp Russell Wiese, Partner, Customs and Global Trade, Hunt & Hunt Lawyers Michael Butler, Tax and Revenue Partner, Finlaysons Philip Diviny, Partner, K& L Gates Dr. Niv Tadmore, Partner, Clayton Utz Alan Jessup, Partner, Piper Alderman

T | 61 2 9247 6000

F | 61 2 9247 6333

W | akolade.com.au

Exhibitors:

Endorser:

Organised by

3RD ANNUAL TRANSFER PRICING AND INTERNATIONAL TAX FORUM 2015

DAY ONE: WEDNESDAY, 13th MAY 2015 8:00 Registration opens 9:00 Opening remarks from the Chair Harry Bernfield, Regional Taxation Manager, Asia Pacific, Brambles EXAMINING THE CHANGING AND DYNAMIC TAX SECTOR 9:10 KEYNOTE ADDRESS The IGT Review into the ATO’s approach to transfer pricing matters • Exploring ATO’s strategic management approach to transfer pricing issues • Practical strategies to improve tax administration • Implications for administration David Pengilley, General Manager, Office of the Inspector- General of Taxation 9:50 Treaty shopping – knowing your boundaries • What is treaty abuse and why is it a problem • Case studies that illustrate treaty abuse • What will be the impact of the BEPS report on treaty abuse Philip Diviny, Partner, K& L Gates

2:20

CASE STUDY How to manage your transfer pricing risks – a practical perspective • Tools to review and monitor the appropriateness of your transfer prices: policies and procedures and documentation requirements • Determining where value is created and how to capture it • When to engage with revenue authorities Joe Hedges, Manager, Taxation, Group Tax, Qantas Airways Limited 3:00 Afternoon Tea 3:20 Practical management of transfer pricing risks • Tools to review the appropriateness of your transfer pricing policies and procedures • Practical ways to mitigate risk and manage stakholders • Experience from the Financial Services sector Jeremy Child, Head of Tax, Australia, RBS Kelly Richmond, Transfer Pricing Adviser, RBS

10:30 SPEED NETWORKING SESSION An exclusive opportunity to network with experts and interact with attendees at the same time • Delegates will be in pairs and have one minute to share their successes, challenges and stories with one another

4:00 The reconstruction power: A storm in a tea cup or a sleeping giant? • Lost in translation? Law goes well beyond Australian and OECD policy guidance • A storm in a tea cup? ATO perspective • What do you do now? Dr. Niv Tadmore, Partner, Clayton Utz

10:45 Morning tea

4:40 Closing remarks from the Chair

11:15 INTERNATIONAL KEYNOTE Strengthening your transfer pricing strategies • Tools to optimise your transfer pricing policies and practices • How will the OECD BEPS impact your transfer pricing operations • Determining how to maximise opportunities and minimize risks Jean-Louis Barsac, Group Head of Transfer Pricing, Alcatel- Lucent, China 12:00 PANEL DISCUSSION How will the OCED BEPS affect your organisation? • Where would we be seeing change within your organisation? • How would ‘Google tax’ work in Australia? • Will this be a positive change for the sector? Panellists: Patrick Thompson, Head of Asian Transfer Pricing, Morgan Stanley Philip Diviny, Partner, K& L Gates Nick Followes, Group Tax Manager, SunRice 12:40 Luncheon STRENGTHENING YOUR GLOBAL CROSS-BORDER TRANSACTIONS 1:40 Adapting to the changing transfer pricing landscape • Preparing your organisation for the changes to come • Tools to optimise your related-parties transactions • How to align your processes and procedures to be inline with the changing landscape Craig Cavanagh, Tax Director, AECOM

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DAY TWO: THURSDAY, 14th MAY 2015 8:00 Registration opens 9:00 Opening remarks from the Chair EXAMINING COMPLIANCE AND OTHER INTERNATIONAL TAX ISSUES 9:10 Documentation: Striking a balance • Establishing a ‘reasonably arguable’ transfer pricing treatment • Settling contemporaneous documentation with limited resources • Benefiting from TR 2014/8 Peter Anthonsen, General Manager Tax, Tabcorp 9:50 INTERNATIONAL CASE STUDY Reviewing your transfer pricing and inter-company transactions • Addressing key challenges about cross-border transactions • Exploring a transfer pricing model that is appropriate for the digital economy • Strategies to effectively deal with change in regulation and legislation Ningyue Wang, Regional Head of Transfer Pricing, Intel, Corporation, Hong Kong

E | [email protected] W | akolade.com.au

13th - 15th May 2015 SYDNEY 10:40 Managing the high cost of compliance for tax teams • How to efficiently prioritise and time the usage of your resources • Analysis of PSLA 2014/3 “Simplified Transfer Pricing record keeping” - can you reduce your workload? • Preparing substantial global documentation and analysis in an efficient manner Darren Baxter, International Tax and Treasury Manager, Billabong Group 11:20 Morning Tea 11:50 Importance of transfer pricing adjustments to the price of goods: Customs duty and GST • What is the link between transfer pricing and customs duty • How to manage the indirect tax opportunities and risks of a transfer pricing adjustment • The current approach of other Australian Customs, the ATO and other countries Russell Wiese, Partner, Customs and Global Trade, Hunt & Hunt Lawyers 12:30 What’s on the tax reform horizon • Status of OECD BEPS Action items • Government responses to the BEPS agenda • Future outlook – what can we expect in the short, medium and longer term? Paul Suppree, Assistant Director, Corporate Tax Association 1:10 Luncheon 2:10 How to effectively respond to an audit by the ATO • Practical strategies to prepare yourself internally • Processes for increased transparency and compliance • The likely impact of the OECD BEPS on the audit process Nick Followes, Group Taxation Manager, SunRice 2:50 Division 815 of the Income Tax Assessment Act 1997: Complying with the strict documentation reporting • How to carry out an effective transfer pricing analysis • Adjusting your internal transfer pricing polices and pricing arrangements • Using the ATO’s risk rating system to minimise the risk of transfer pricing arrangements being targeted Michael Butler, Tax and Revenue Partner, Finlaysons 3:30 Afternoon Tea 4:00 The goal to reach: A fairer, simpler tax system • The importance of being more transparent • Our role in the changing Australian tax landscape • How can tax practitioners adapt to the changes to come Peter Adams, Spokesperson, Taxpayers Australian 4:40 PANEL DISCUSSION Transfer pricing in the context of a complex tax structure • Were the companies simply taking advantage of opportunities under the current law? • Exploring their tax structures? • What can we learn from these cases? Panellists: Dr. Niv Tadmore, Partner, Clayton Utz Michael Butler, Tax and Revenue Partner, Finlaysons Ningyue Wang, Regional Head of Transfer Pricing, Intel Corporation 5:20 Closing remarks from the Chair and conference adjourns

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F | 61 2 9247 6333

POST-CONFERENCE WORKSHOPS: DAY THREE: FRIDAY, 15th MAY 2015 WORKSHOP A: 9:00- 12:30

How to strengthen compliance and optimise your transfer pricing strategies This workshop will provide you with tools to effectively handle the transfer pricing aspects of your cross-border related party transactions. It will also focus on the importance of being transparent and sustainable measures to meet the substantial documentation requirements. You will gain: • Strengthening your inter-company financial transactions • Strategies to optimise your international tax compliance • Insight into recent case developments and their practical implications • Tools to increase transparency within your organisation • Cost-effective methods to handle the documentation requirements Alan Jessup, Partner, Piper Alderman

Alan is a partner with the firm Piper Alderman. He is a Chartered Tax Adviser and holds Masters Degrees in both Law and Taxation. He is the author of the book “Managed Investment Schemes” © Federation Press 2012. Alan provides advice on stamp duty and income tax aspects of business transactions including business restructures and has extensive experience in relation to international tax matters including transfer pricing issues involved in cross border acquisitions and dealings.

12:30 - 1:30 Lunch

WORKSHOP B: 1:30- 5:00

Tools to strengthen your transfer pricing and intragroup financing transactions This workshop will provide you with tools to optimise your transfer pricing strategies for the wave of change within the tax sector. It will focus on recent documentation requirements and transfer pricing of intragroup financing transactions. You will: • Gain an insight into group financing models • Learn how to apply the arm’s length principle • Examine the preparation of effective compliance documentation • Consider the practical implications of recent case law developments • Obtain a deeper understanding of intra-group finance guarantees and loans Michael Butler, Tax and Revenue Partner, Finlaysons

Michael has spent over 25 years working solely in taxation law. His expertise at state, federal and international levels includes income tax, capital gains tax, GST, WET, fuel tax credits and carbon tax, as well as stamp duty, payroll tax and land tax. This expertise is acknowledged in the 2013 edition of Best Lawyers Australia. His special interests include property and mining taxation, estate and business succession planning, international tax matters and tax dispute resolution. He has advised a range of clients on the tax, GST and stamp duty implications of property subdivisions and developments, and mining operations and joint ventures, and has helped private clients to deal with the difficult tax and family issues that arise during asset division.

(Lunch is provided to those delegates registered for both Workshop A and Workshop B) *You can gain up to 12 CPD hours upon attending this conference. We will provide you with a certificate of attendance and you can claim your CPD hours from the CPA and other related associations.


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VIP CODE

3RD ANNUAL TRANSFER PRICING AND INTERNATIONAL TAX FORUM 2015

ACC07 REGISTRATION FORM EARLY BIRD DISCOUNTS

REGISTRATION FEE

STANDARD PRICE

Register and book before:

(including GST)

13 Mar 2015

03 Apr 2015

17 Apr 2015

01 May 2015

$1,978.90

$2,088.90

$2,198.90

$2,308.90

$2,528.90

B ✔

$2,638.90

$2,748.90

$2,858.90

$2,968.90

$3,188.90

✔

$2,968.90

$3,078.90

$3,188.90

$3,298.90

$3,518.90

$2748.90

$2,858.90

$2,968.90

$3,078.90

$3,188.90

$3,408.90

$3,518.90

$3,628.90

$3,738.90

$3,848.90

$3,738.90

$3,848.90

$3,958.90

$4,068.90

$4,178.90

Standard Rates Conference Only Conference plus 1 workshop

A

or

Conference plus 2 workshops

Solution Provider Rates Conference Only Conference plus 1 workshop

A or B ✔

Conference plus 2 workshops

✔

SAVE! Choose between: 1: EARLY BIRD DISCOUNT. Register and pay by a deadline indicated above to achieve up to 20% SAVINGS on the Standard Rate. Registrations received without payment are ineligible for an Early Bird Discount and will be charged at the Standard Rate. 2: TEAM DISCOUNT. ( i ) Register 3 delegates and receive a $1000 DISCOUNT off the Standard Price ( ii ) Register 4 delegates and receive the 5th ticket FREE off the Standard Price All group registrations must be from the same company, at the same time and for the same event. Registrants must choose between the most advantageous discount option.

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