Global Transfer Pricing Forum September Park Hyatt Hotel, Washington DC

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14TH ANNUAL Global Transfer Pricing Forum September 22-23 2014 Park Hyatt Hotel, Washington DC TAKE PART IN TWO DAYS OF

largest multinationals Discover how your peers are dealing with specific transfer pricing matters and benchmark your own

debates on the most problematic areas of transfer pricing and find out how to tackle them in your business Hear about transfer

1 14TH ANNUAL Global Transfer Pricing Forum September Park Hyatt Hotel, Washington DC TAKE PART IN TWO DAYS OF INTERACTIVE DISCUSSIONS TO ENABLE YOU TO: Expand your business contacts by networking with the tax directors of the world s largest multinationals Discover how your peers are dealing with specific transfer pricing matters and benchmark your own strategies Get the latest updates on the OECD s BEPS project and find out what key decision makers will do next Listen to debates on the most problematic areas of transfer pricing and find out how to tackle them in your business Hear about transfer pricing policy initiatives from various global organisations and what they mean for your business In association with: TO REGISTER, OR FOR MORE INFORMATION:

14th Annual Global Transfer Pricing Forum September 22-23 2014 Park Hyatt Hotel, Washington DC The 14th annual International Tax Review and TPWeek Global Transfer Pricing Forum will be held in

Expert insights will be heard from the US Department of Treasury and the World Bank Group as well as perspectives from some of the world s largest multinationals including Hewlett-Packard, Nissan and

This year s special focus will not only include the G20 and OECD base erosion and profit shifting (BEPS) project but will also look at the impact on the compliance burden of multinational taxpayers

Delegates will also benefit from high-level discussions on tax issues in the digital economy, supply chain restructuring and dispute resolution and controversy management.

2 14th Annual Global Transfer Pricing Forum September Park Hyatt Hotel, Washington DC The 14th annual International Tax Review and TPWeek Global Transfer Pricing Forum will be held in association with Deloitte at the Park Hyatt Hotel in Washington DC on September 22 and 23. Expert insights will be heard from the US Department of Treasury and the World Bank Group as well as perspectives from some of the world s largest multinationals including Hewlett-Packard, Nissan and Caterpillar. This year s special focus will not only include the G20 and OECD base erosion and profit shifting (BEPS) project but will also look at the impact on the compliance burden of multinational taxpayers from the possible introduction of country-by-country (CbC) reporting. Delegates will also benefit from high-level discussions on tax issues in the digital economy, supply chain restructuring and dispute resolution and controversy management. Panel debates will feature speakers from government and in-house tax departments, as well as top transfer pricing advisers where delegates can expect to hear how best to cope with the compliance burdens and how to combat new audit approaches from government. In addition, this year will hold industry-specific break-out panels, to allow for a more targeted approach to transfer pricing planning. Who should attend: Corporate tax directors Revenue officials Finance directors Corporate transfer pricing managers Private practitioners Transfer pricing economists Join the Global Transfer Pricing Forum group on LinkedIn for the latest news about the conference. Search: Global Transfer Pricing Forum 2014 Park Hyatt Hotel th St NW, Washington, DC 20037, United States Special room rates are available for attending delegates for September from USD319 + tax per night. To book your room visit: *Please note that all delegates are responsible for their own accommodation and travel. Media partners TO REGISTER, OR FOR MORE INFORMATION:

Day 1 September 22, 2014 8.30 Registration and breakfast 9.

10 Keynote address Sam Maruca, Former Director, Office of Transfer Pricing Operations, US Internal Revenue Service 9.

Without final documents and guidance to react to, taxpayers are still trying to prepare for possible changes to the way they do business and are looking to review the transactions they have already

3 Day 1 September 22, Registration and breakfast 9.00 Chair's introduction and opening remarks Sophie Ashley, Managing Editor, TPWeek Todd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte 9.10 Keynote address Sam Maruca, Former Director, Office of Transfer Pricing Operations, US Internal Revenue Service 9.30 BEPS: A general update BEPS is still creating debate about its potential impact on taxpayers. Without final documents and guidance to react to, taxpayers are still trying to prepare for possible changes to the way they do business and are looking to review the transactions they have already put in place for possible risks to audit. What are the general debates that have arisen during the BEPS project in the past year? Recommendations for action based on new material released by the OECD and its commentators Tim Tuerff, Partner, Deloitte (moderator) Will Thompson, Director of Transfer Pricing, Brown-Forman David Forst, Partner, Fenwick & West Roy Herzgsell, Head of Transfer Pricing, Colfax Group Coffee Digital economy issues: Where are we heading? The OECD has published a discussion draft on the "Tax Challenges of the Digital Economy", relating to Action 1 (address the tax challenges of the digital economy) of the action plan (AP) on base erosion and profit shifting (BEPS). This new OECD discussion draft examines the evolution over time of information and communication technology (ICT), including emerging and possible future developments. Discuss the spread and impact of ICT across the economy Share examples of new business models Identify key features of the digital economy Keith Reams, Partner, Deloitte (moderator) Paul Morton, Head of Group Tax, Reed Elsevier Group Deborah Van Horn, Senior Director of Tax, IDT Integrated Device Technology Mike Bowes, Transfer Pricing Director, Deloitte Lunch Keynote address: The future of transfer pricing documentation Tracey Rossow, Senior Solution Consultant, Thomson Reuters ONESOURCE Industry panel focus: TMT, life sciences, manufacturing Industry expertise is becoming more and more important in the transfer pricing area. This panel will help you understand why and suggest how to address industry dynamics, competitive landscape, innovations, and disruptions in the pricing models. The industry panel will introduce you to the latest industry-specific pricing models and trends within key industry groups: Technology, media and telecommunications, energy, life sciences, manufacturing and consumer products. Kristine Riisberg, Principal, Deloitte (moderator) Heather Crowder, Global Head of TP, Conoco Philips Ognian Stoichkov, Director, Global Transfer Pricing, PepsiCo Aydin Hayri, Principal, Deloitte Kaoru Dahm, Principal & Transfer Pricing Economist, Deloitte Coffee Keynote address Randall Fox, Transfer Pricing and APA Specialist, World Bank Group Hot topics in global transfer pricing While BEPS is holding centre stage in the global transfer pricing debate it is not the only international issue. Various regulation changes in Latin America have had an impact on how taxpayers organise their global affairs. The European Commission is also releasing new reports and launching investigations into suspected transfer pricing abuse. In Asia, China is relaxing its stance towards OECD guidelines and India released a raft of new transfer pricing measures in its 2014 budget, including acceptance of the interquartile range and use of multiple year data. Shanto Ghosh, Partner, Deloitte (moderator) David García Morales, International Tax Lawyer, Ecopetrol Randall Fox, Transfer Pricing and APA Specialist, World Bank Group Ramón López de Haro, Partner, Deloitte Close of day one Cocktail reception All Global Transfer Pricing delegates and speakers are welcome to join us for drinks, canapés and networking Sponsors: Exhibitor: TO REGISTER, OR FOR MORE INFORMATION:

4 Day 2 September 23, Registration and breakfast 9.00 Chairman s opening remarks Ralph Cunningham, Managing Editor, International Tax Review Todd Wolosoff, Global & US Transfer Pricing Managing Partner, Deloitte 9.10 Keynote address Robert Stack, Deputy Assistant Secretary (International Tax Affairs), US Department of Treasury 9.30 BEPS: A detailed discussion of recently released final guidance on TP documentation and countryby-country reporting Entrenched in the BEPS debate is the concept of country-by-country (CBCR) reporting. CBCR has evolved from a fringe concept to a global reality in a relatively short space of time. It could mean that individual jurisdictions have a better idea of a company's global tax payments but it could also implicate a significant compliance burden for taxpayers if not handled correctly. What will it mean for multinational companies and how will it affect their transfer pricing compliance? Discuss the controversial aspects of CBCR whilst giving tips to taxpayers about the best ways to manage its impact on their company Mark Nehoray, Managing Partner, Deloitte (moderator) Sameer Chaudhary, Americas Transfer Pricing Manager, Hewlett Packard Inga Kondrataite, Head of Transfer Pricing, AMIE (Africa, Middle East, India and Europe), Nissan Andrew Kim, Partner, Fenwick & West Darcy Alamuddin, Partner, Deloitte Coffee The profit split method While the US transfer pricing regulations refer to the "profit split method", there are two methods that fall under this heading. This panel will focus on: Value creation Intangible issues Different models Location specific advantages Rob Plunkett, Principal, Global & US Financial Service TP Leader, Deloitte (moderator) Andrea Bonzano, Head of Tax, Fiat Frank Schoeneborn, Head of Global Operational Transfer Pricing Management, Merck Group Boris Nemirov, Tax Principal/Partner, Transfer Pricing, Deloitte Lunch Keynote address A step forward to mitigate Transfer Pricing risks a global ISO certification on TP Dr. Knut Olsen, Global Tax Practitioner & Adjunct Tax Professor, Dr. K. Olsen Global Tax Consultant Supply chain restructuring and intangible planning in the current environment Considering the uncertainty surrounding intangible assets, supply chain restructuring has become an even more risky business for taxpayers in recent years. Focus on business transformations to create entrepreneurial structures within a group of companies Discuss best practices and determine the different types of intellectual property a company could be dealing with How these different types of IP will affect restructuring John Wells, Principal, Deloitte (moderator) Dr Napoleão Dagnese, Head of International Tax, OC Oerlikon Don Maher, Director of Tax Planning, The Dow Chemical Company Michael Gilson, Partner, Deloitte Will Thompson, Director of Transfer Pricing, Brown-Forman Coffee Dispute resolution and controversy management: Emerging issues Each year, more and more rulings are being made in various high courts and tax courts around the world. All of these rulings, if not binding in law outside of the particular country, have lessons for taxpayers; slowly helping to build a clearer picture about the art of transfer pricing. Hear from notable transfer pricing case studies Cover new tactics for audit defence, taking a long-term view on the risks of transfer pricing controversy In-house counsel will provide their first-hand experiences Rob O'Connor, Partner, Deloitte Katherine Amos, VP, TP Strategy, EATON Keith Richey, International Tax Counsel, Xylem Inc Cindy Hustad, Director, Tax Controversy Services, Deloitte James R. Gadwood, Sullivan & Cromwell Close of day two Americas Tax Awards September 18, 2014 Grand Hyatt, New York For further information and table bookings, contact Megan Poundall at mpoundall@euromoneyplc.com. TO REGISTER, OR FOR MORE INFORMATION:

5 1 REGISTER (Please tick one box) In-house tax Advisers/Consultants/ executives Private Practitioners Super early bird rate (before June ) 795 / USD ,295 / USD 2,095 Early bird rate (before July ) 995 / USD ,495 / USD 2,395 Standard rate (after July ) 1195 / USD ,695 / USD 2,695 Total remittance I would like to register for International Tax Review s 14th Annual Global Transfer Pricing Forum September 22-23, 2014 Park Hyatt Hotel, Washington D.C. EARLY BOOKING RATES AVAILABLE Save up to 400/$700 2 YOUR DETAILS FOR REGISTRATION (Please print) DELEGATE 1 Name Job title Company Address DELEGATE 2 Name Job title Company Address Postcode Country Tel Fax 3 METHOD OF PAYMENT Payment must be received before the conference date to guarantee your place. Please tick box to select payment method and sign agreement in box Bank transfer quoting reference number Account ; Sort code IBAN no GB 97 LOYD Lloyds Bank TSB Plc, City Office, PO Box 72, Bailey Drive, Gillingham Business Park, Gillingham, Kent, ME8 0LS, UK $ Account ; Sort code IBAN no GB 29 LOYD Account ; Sort code IBAN no GB 25 LOYD SWIFT address: LOYD GB2 LCTY Postcode Country Tel Fax Please find cheque enclosed (please make payable to Euromoney Institutional Investor PLC) To make a payment by credit card, please register and pay online at or call +44 (0) Please note that in completing this booking form you undertake to adhere to the cancellation and payment terms listed below. Signature: Position: Date: The information you provide on this form will be used by Euromoney Institutional Investor PLC and its group companies ( we or us ) to process your order and deliver the relevant products/services. We may also monitor your use of the website(s) relating to your order, including information you post and actions you take, to improve our services and track compliance with our terms of use. Except to the extent you indicate your objection below, we may also use your data (including data obtained from monitoring) (a) to keep you informed of our products and services; (b) occasionally to allow companies outside our group to contact you with details of their products/services; or (c) for our journalists to contact you for research purposes. As an international group, we may transfer your data on a global basis for the purposes indicated above, including to countries which may not provide the same level of protection to personal data as within the European Union. By submitting this order, you will be indicating your consent to the use of your data as identified above. Further detail on our use of your personal data is set out in our privacy policy, which is available at or can be provided to you separately upon request. If you object to contact by telephone, fax, or , or post, please tick the relevant box. If you do not want us to share your information with our journalists, or other companies please tick the relevant box. TO REGISTER: ONLINE TEL +44 (0) FAX +44 (0) MAIL Alicia Sprott International Tax Review Nestor House, Playhouse Yard London, EC4V 5EX, UK CANCELLATION POLICY: If you cannot attend you must cancel your registration in writing by 25 August 2014 to receive a refund less a 10% administration charge. Cancellations received after 25 August, or no shows, are liable for the full conference fee (where applicable). You may send a substitute to attend in your place at no extra charge, however we must know by 15 September 2014 via . We cannot accept verbal cancellations. If you make your booking online, by or via the telephone, you are automatically adhering to our terms and conditions. ADMINISTRATIVE INFORMATION REGISTRATION: The registration fee includes participation in the forum on both days, documentation materials, breakfast, coffee breaks, lunches and a cocktail reception at the end of day one. All delegates are responsible for their own accommodation and travel. PAYMENT: All registration fees must be received in full prior to the event date. TRAVEL & ACCOMMODATION: Delegates are responsible for the arrangement and payment of their own travel and accommodation.

15th anniversary Global Transfer Pricing Forum & 25 September 2015, Park Hyatt Hotel, Washington DC

15th anniversary Global Transfer Pricing Forum 2015 JOIN 200+ TAX EXECUTIVES, TRANSFER PRICING PROFESSIONALS AND TAX AUTHORITIES TO: HEAR HIGH-LEVEL KEYNOTE SPEECHES: Insights from Chair of the Business