IBFD Course Programme Transfer Pricing: Financial Services Industry
Overview and Learning Objectives Digitalization has changed and will continue to change business models. This will impact the global value chains of multinational enterprises. At the same time, financial services companies are growing through partnerships with tech giants and start-ups. Simultaneously, the OECD implemented the recommendations resulting from the OECD BEPS Action Plans and the European Union and United Nations followed suit. In addition, countries have implemented unilateral rules. Furthermore, both the US tax reform and the Brexit have created and are expected to create incentives and disincentives for the financial services industry and to impact future investments and divestments. Like with other multinationals, all of the aforementioned developments have a potential impact on companies in the financial services industry, but some specific actions may have a larger impact on companies active in the financial services industry than on companies active in other sectors. This advanced-level, interactive masterclass consists of case studies and sharing best practices. It is designed for participants who are active in the financial services industry, have knowledge of transfer pricing and want to gain more in-depth understanding of the implications of BEPS for their day-to-day practice. Participants will receive a roadmap of the changes that each of the BEPS reports on transfer pricing brings and how these reports are interrelated. Field of Study Taxes Who Should Attend? The course is suitable for transfer pricing advisers, lawyers, accountants, and in-house transfer pricing managers active in the financial services industry. The course will enable participants who have a good understanding of transfer pricing principles to gain updated insight into the key transfer pricing issues faced by the industry in today's rapidly changing tax and financial services environment. The focus of the course will be on practical approaches to manage and mitigate transfer pricing compliance risks. Course Level and Prerequisites This is an advanced-level course. Participants taking this course will be expected to have a good understanding of transfer pricing issues faced by the financial services industry. 2
Day 1 08.30-09.00 Registration 09.00-09.20 Welcome and IBFD Overview 09.20-10.00 Current Developments Impacting Financial Services Discussion of the future of the financial services industry including trends, strategies, ideas and views. 10.00-11.00 Structural Change in Response to Significant Issues Disrupting the Financial Services Market This session will consist of a multidisciplinary tax discussion with transfer pricing, direct tax and VAT professionals constituting the panel. This session will address the question on how transfer pricing professionals can align their approach to the tasks with those of their tax colleagues. The following topics and questions will be addressed: Brexit US tax reform Events in 2019 as yet unknown What are the key business changes seen in the financial services industry in response to these issues? What are the broader tax challenges resulting from these changes? How does the transfer pricing team respond to these transformations and contribute to a coordinated tax response? 11.00-11.20 Break Refreshments 11.20-12.45 Key Regulatory Developments and Their Impact on Transfer Pricing in Financial Services A discussion group will update you on the significant regulatory developments. Questions such as how transfer pricing policies should be amended to reflect these developments will be addressed. In addition, pitfalls such as situations in which the transaction characterization and the intercompany allocation of profit are inconsistent with the regulatory positions will be identified. Panel pairs a regulatory expert and a transfer pricing practitioner will discuss: Banking Insurance Investment management 12.45-14.00 Lunch 3
14.00-15.15 Changing Business Models for Risk Management Focus on Emerging Technologies and Changes in People Functions Part 1: Industry Perspective This industry session will provide tax and transfer pricing professionals with a commercial insight into the future of the industry, based on disruptive business model changes, and help you to redefine your thinking in terms of the substance, people functions and the management and control of risks. It will be led by guest speakers from the industry who will give you an updated view of the process of risk control and management and the role of artificial intelligence and machine learning in the automation of risk-taking decisions. 15.15-15.30 Break Refreshments 15.30-17.00 Changing Business Models for Risk Management Focus on Emerging Technologies and Changes in People Functions (continued) Part 2: Transfer Pricing Workshop This session will be conducted in a discussion group format with participants in smaller breakout groups to reflect on the implications from the industry perspective and exchange ideas on substance and the interaction between traditional people functions and technology-supported contributions to the business models in the financial services industry. 4
Day 2 09.00-09.30 Welcome and Recap of Day 1 09.30-10.30 Vision of the Financial Services Industry of the Future Discussion of the future of the financial services industry including interesting trends, strategies, ideas and views. 10.30-10.50 Break Refreshments 10.50-12.00 Update on the OECD Guidance on Financial Transactions and the Impact on Financial Institutions This session will address: Update on the latest OECD guidance on financial transactions The allocation or attribution of capital and the return on capital, also considering the link with the relevant significant people functions Implications of the single point of entry regulations and the implications for intra-group financing Funds transfer pricing and the economic cost of liquidity 12.00-13.00 Workshop on Financing Transactions Facilitators will start the session by asking the participants to identify the issues of greatest interest or concern to them and will focus the discussion accordingly. This session will be conducted in a discussion group format with participants in smaller breakout groups to share perspectives on the impact of the latest guidance on their institutions. 13.00-14.15 Lunch 14.15-15.30 Update on Transfer Pricing Audits and Disputes in the Financial Services Industry This session will address the following topics: Update on tax authority strategy and key areas of focus in the industry Latest views on the best ways to avoid disputes Successful strategies to defend and support your position when challenged 15.30-15.50 Break Refreshments 15.50-16.50 Integration of Transfer Pricing with the Direct and Indirect Tax Disciplines 5
This session will comprise transfer pricing as well as direct and indirect tax professionals exploring best practices in working together effectively. The discussion topics will include: Transfer pricing decisions that may have a large VAT impact Direct tax impacts of transfer pricing arrangements How can transfer pricing professionals stay on top of broader tax developments to ensure they support the group's overall tax policies? 16.50-17.00 IBFD Closing Remarks 6