30 Oct 2018IBFD-PwC Transfer Pricing Seminar: Mastering the IP Life Cycle - Grasping the Intangible
- Amsterdam - The Netherlands
- IBFD-PwC Transfer Pricing Seminar: Mastering the IP Life Cycle - Grasping the Intangible
The Transfer Pricing Substance Masterclass will be held the day after this event from 31 October – 2 November 2018. Join us for case studies and sharing best practices in an advanced-level interactive workshop setting. More information here.Throughout the years the importance of intangible assets has increased. This is shown in the balance sheets of multinationals, the reports produced by international organizations such as the OECD, EU and UN and the unilateral measures taken by countries. Business models of multinationals have changed and this impacts the global value chains of companies. Due to the changed guidance of the various international organizations, transfer pricing models and transfer pricing documentation needs to be adjusted.
This seminar consists of panel sessions in which the changed guidance, case studies and case law will be discussed. During this conference best practices will also be shared. During and after the conference there will be ample opportunity for networking. The speakers at the seminar include:
This seminar coincides with the launch of the upcoming book: Mastering the IP Life Cycle from a Legal, Tax and Accounting Perspective. Stay tuned for more details regarding this book launch.
- Önder Albayrak - Deputy Head of Transfer Pricing, Genzyme-Sanofi, The Netherlands
- Anuschka Bakker - Manager of the Transfer Pricing and Specialist Knowledge Group, IBFD, The Netherlands
- Sander Biemans - Global Tax Director, GrandVision NV, The Netherlands
- Irene Burgers - Professor of International Tax Law, University of Groningen, The Netherlands
- Robert Danon - Professor of International Tax Law, University of Lausanne, Switzerland
- Stefan De Baets - Senior Counsel Transfer Pricing, PwC, The Netherlands
- Sandra Esteves - Director Global Transfer Pricing/TESCM, SABIC, The Netherlands
- Annemiek Kale - Global Head of Tax, Arla Foods, Denmark
- Guglielmo Maisto - President IFA Italian Branch and Professor international and comparative tax law, Università Cattolica di Piacenza, Italy
- Isabel Verlinden, Global Transfer Pricing Leader, PwC, Belgium
- Ruxandra Vlasceanu - Principal Associate, IBFD, The Netherlands
09:00 - 09:30 Registration
09:30 - 10:00 Welcome and Introduction
10:00 - 11:20 Panel Discussion 1: Deep Dive into Big Data Value Chain
In this day and age, data is gathered, cleaned, processed and monetized. This panel will discuss where “value creation” sits in the current age of artificial intelligence (AI) and machine learning (terms that are often used interchangeably) in which computers crunch vast quantities of data to find patterns and make predictions without being explicitly programmed (by human beings) to do so. Large quantities of data, more sophisticated algorithms (that are self-reinforcing) and sheer computing power have given AI greater force and capability. The outcomes are comparable to what an army of statisticians with unlimited time and resources may come up with, but they are achieved far more quickly, cheaply and efficiently. Also block chain is used more and more in business processes. Due to the aforementioned, supply chains are getting shorter and shorter and as a transfer pricing practitioner, one may ask how this translates in DEMPE, if at all. This panel will discuss the international developments and case studies.
11:20 - 11:40 Coffee Break
11:40 - 13:00 Continuation
13:00 - 14:30 Lunch and Networking
14:30 - 15:50 Panel Discussion 2: The Future of Intangibles and Tax Planning through a Legal Lens
MNEs may be focusing on the DEMPE functions while dealing with transfer pricing and intangibles. The domestic and treaty-based general anti-abuse rules (GAARs) and principal purpose tests (PPTs), such as the ones in the OECD Multilateral Instrument and the OECD Model, should also be on the radar of MNEs. In addition, MNEs need to take into account the EU Anti- Avoidance Directive, which is targeting, among other issues, low-tax entities receiving royalties or any other income generated from intellectual property. Last but certainly not least the danger of State aid cases is addressed.
15:50 - 16:10 Coffee Break
16:10 - 17:30 Panel Discussion 3: Transparency and End-to-End Implementation
How can MNEs implement operational transfer pricing tools that focus on standardizing, automating and implementing transfer pricing as much as possible in day-to-day operations? How can you identify transfer pricing risks, determine transfer pricing adjustments, and avoid indirect tax issues and large year-end adjustments and be proactive rather than reactive? How to deal with uncertain tax positions in relation to intangible assets under IFRS and US GAAP? How to deal with tax credits and government grants for tax accounting purposes related to R&D? These and other items will be discussed in this panel.
17:30 - 19:30 Social Event
Önder Albayrak is Deputy Head of Transfer Pricing at Genzyme-Sanofi. He studied Dutch and Tax Law at the University of Utrecht. He started his career in the Multinationals Tax department of Ernst & Young and moved in 2002 to the Transfer Pricing & TESCM team of Ernst & Young, Amsterdam ...
Anuschka Bakker is the Manager of the Transfer Pricing and Specialist Knowledge Group of IBFD in Amsterdam. In addition, she acts as the Cluster Manager for the transfer pricing courses offered by IBFD International Tax Training ...
Sander Biemans is Group Tax Director for GrandVision NV, a global leader in optical retail, operating in over 40 countries. He heads the group tax network within the finance organization of GrandVision and as such is responsible for its international tax affairs ...
Irene J.J. Burgers is Professor of International Tax Law at the Faculty of Law of the University of Groningen, the Netherlands, and Professor of Economics of Taxation at the Faculty of Economics and Business of the same university. Her focus is on tax treaty issues and on cooperative compliance ...
Stefaan is a senior counsel in the field of transfer pricing since 1 January 2016. He specializes in the avoidance and settlement of transfer pricing controversy, further development of the transfer pricing market, promoting the key presence of PwC ...
Robert J. Danon is Professor of International Tax Law at the University of Lausanne, Switzerland, where he heads its Tax Policy Center. He is a member of several professional international tax organizations and currently serves as the Chairman ...
Sandra Esteves is the Director Global Transfer Pricing/TESCM at SABIC, a worldwide leading chemicals company. Before joining SABIC, she worked in the EY and the Deloitte International Tax and Transfer Pricing departments in Portugal and Spain ...
Annemiek Kale is Global Head of Tax at Arla Foods amba in Denmark. Arla Foods is an international dairy cooperative that is the largest dairy producer in Scandinavia. The tax team of Arla Foods is spread over multiple locations ..
Guglielmo Maisto founded Maisto e Associati in 1991. He is a Professor of international and comparative tax law at the Università Cattolica di Piacenza. He is President of the Italian Branch of the International Fiscal Association (IFA ...
Isabel Verlinden is a Brussels-based International Tax Partner heading up PwC’s Global Transfer Pricing practice. She has gathered first-hand knowledge of the TP challenges faced by companies that operate across the globe in over 25 years ...
Ruxandra Vlasceanu is a Principal Associate in IBFD’s European Knowledge Group, serving as managing editor of the Mergers & Acquisitions publication and author/editor of other IBFD publications. She is also an instructor at IBFD ...
This seminar will be conducted in joint collaboration with PwC.
IBFD Head Office
1019 DW Amsterdam
Hotel recommendation will be sent after registration. For group bookings please contact Lyn Balster at email@example.com.
Course fee and registration details
EUR 295 (VAT excl.)
USD 354 (VAT excl.)
Early Bird Discount: a 30% discount will be applied for registrations received 60 days or more before the commencement of the seminar (cannot be used in conjunction with other discounts).
Combination discount, available after expiration of the Early Bird Discount: register simultaneously for both the seminar and the Transfer Pricing Substance Masterclass and receive a 20% combination discount. This discount is only available via the webshop. Place both products in your cart – your discount will be applied automatically.
Discounts are non-cumulative, the largest discount applicable will be granted.
The fee covers participation in the seminar, all materials, lunch, coffee/tea, refreshments as well as participation in the social event following the technical discussions. The costs of accommodation and transport are not covered. If you have any other questions with regards to attending the seminar, travel arrangements, payments and cancellations, please consult our FAQ and Terms and Conditions.
Who should attend?
The conference is suitable for transfer pricing advisers, lawyers, accountants, in-house transfer pricing managers/directors, controllers and finance staff.
Interactive seminar - "Group Live"
This is an interactive seminar, participants will have the opportunity to actively contribute to the conversation and respond to the keynote speeches and panel discussions.
Continuing Professional Education
Recommended CPE points for this seminar: 6 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.