Protecting Intra-Group, Cross Border Transfers of Intangible Assets from Excess Tax

Tue 5 December 2017

The Caledonian Club 9 Halkin Street London SW1X 7DR

Answers to 13 Thorny Questions: Directly from 8 Supremely Talented Lawyers and Accountants

5hrs CPD

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  1. Registration and coffee

  2. Chairman's Introduction

    Protecting intra-group, cross border transfers of intangible assets from excess tax

    Chaired by: Philip Baker QC

    Philip is “the most prominent person on tax treaties internationally”. He is author of "Double Taxation Conventions" and Editor of the International Tax Law Reports. His "reputation is outstanding".

  3. ​State aid

    What are the Apple and Fiat state aid decisions telling us about the EC unique version of the arm's length standard?

    Can any “sweetheart deal” with a multi-national stand up to state aid scrutiny?

    Answered by: Conor Quigley QC

    Conor is "without doubt the leading silk in the area of state aid". He is a "brilliant advocate", "very commercial" and "solution-driven". He is author of "European State Aid Law and Policy".

  4. ​BEPS Actions 8-10

    How are you to apply (with any certainty) newly emerging valuation concepts and approaches when pricing hard-to-value intangibles, with reference to BEPS transfer pricing Actions 8-10?

    Answered by: Dr Daniel Beeton of Duff and Phelps

    Daniel is one of the “World’s Leading Transfer Pricing Advisers”. He provides guidance to HMRC, the Capital Markets Tax Committee and the BBA. He is Editor of the BNAI's Transfer Pricing Forum Journal.

  5. Morning coffee

  6. Litigating a transfer pricing case

    What are the critical factors when litigating a transfer price case?

    Answered by: Francis Fitzpatrick QC

    Francis acted in the UK's first substantive transfer pricing case, DSG Retail Ltd v HMRC. He is author of "Transfer Pricing and Shareholders". He "exudes star quality" for his "compelling courtroom presence".

  7. Cash-pooling

    Where is the line between cash pooling policies and inter-company debt, with reference to the rates you set and the potential for disguised long-term loans?

    How might secondary adjustments fit in?

    Answered by: Douglas Keel of Radcliffe Chambers

    Douglas is formerly a tax partner with PwC. He specialises in international tax planning. He is immensely experienced, a great communicator and right at the forefront of developments.

  8. Over-run

  9. Lunch

  10. Intangibles valuations: conversations with HMRC

    What is HMRC’s approach?

    What are the best methods for engaging with HMRC?

    Answered by: Lyndsay MacGregor of Deloitte LLP

    Lyndsay has negotiated and agreed values with HM Revenue & Customs for hundreds of clients across a broad industry base. She is co-author of "Tolley’s Tax Planning: Valuation of Intangible Assets".

  11. BEPS MLI Arbitration and SDR

    Despite all the noise, is arbitration actually the panacea for securing a final resolution to cross border tax disputes?

    Could SDR techniques more effectively complement the MAP process?

    Answered by: Peter Nias of Pump Court Tax Chambers

    Peter has advised multinational companies and foreign tax authorities on the use of ADR /SDR facilitation and mediation techniques to assist the resolution of cross-border bilateral and multilateral tax disputes both in the pre-MAP period and during the MAP process.

  12. ​Commercial objectives

    Is there any wriggle room as worldwide tax authorities adopt similar approaches to transfer pricing and sharing information, with reference to the EC’s stance on APAs and the OECD’s stance on BEPS?

    Answered by: Joel Cooper of DLA Piper

    Joel is formerly the World Bank's lead for the provision of transfer pricing and international tax technical assistance to member countries. He is co-head of the International Transfer Pricing Group.

  13. Over-run

  14. Close of conference

** All speaker quotes are taken from Chambers Directory, Who's Who Legal and Legal 500