17-18 OCTOBER 2019FRANKFURT, GERMANY

6th ANNUAL

CORPORATE TAX SUMMIT

SPEA

KERS

CHAI

RMEN

EMINE CONSTANTINGlobal Head of Accounting & TaxTMF Group

LUIS CARRILLOSenior Director – Tax & Transfer Pricing SolutionsBureau Van Dijk – A Moody’s Analytics Company

MARK JOHNSONCo-Head of Unit, Tax Certainty / CbC ReportingOECD

ANDREAS RIEDLPartner Transfer Pricing & Head of TP TechnologyWTS

FURHERR GEBHARDAuditor and Tax AdvisorLeitnerLeitner GmbH

PAUL DALYPartner, Head of Transfer PricingBDO

YVES HERVEManaging DirectorNERA Economic Consulting

BRIGITTE BAUMGARTNERIndependent Transfer Pricing ExpertTP Baumgartner

KEY

TOPI

CS

• Transfer Pricing, User Participation, and Attribution of Profits to Virtual Permanent Establishments• CbCR, SAF-T, e-invoicing – exploring digital initiatives• International tax disputes – MAP, Arbitration, APAs• Recent developments in ICAP pilot

• Aligning tax KPIs/targets with the overall corporate• Tax function automation• A detailed look into BEPS and MLI• Staff turnover and education – building an effective tax team for the future

PHILIP DE HOMONTAssociate DirectorNERA Economic Consulting

PLATINUM SPONSOR GOLD SPONSOR SILVER SPONSOR BRONZE SPONSOR

CMYK

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WOLFGANG KLOSTERPartnerBDO

RAFFAELE PETRUZZIManaging DirectorWU Transfer Pricing Center

LARS VON JESCHEPartner, International Corporate TaxBDO

EDUARDO R. FLÖRING JR.Head of Transfer PricingTheo Müller Group

STANISLAVA MANOLOVATax ManagerPORR AG

DONATA KORENSenior Lead of Tax TeamZalando

HARM J OORTWIJNSenior Tax Structuring, Reporting and Compliance Whirlpool

MARK HOUTZAGEREMEA Tax LeaderStarbucks

MARIA GRIGORYEVASenior ManagerTPA GlobaI

XAVIER XIVILLEPartner, Lawyer, Economist Cuatrecasas

ÓSCAR BERTRÁNPartner Cuatrecasas

XAVIER CAMPSSenior Tax ManagerElectronic Arts (EA)

KATE BUSHBYInternational Tax LeadTransferWise

MARC MOKRABGlobal Head of TaxTechnicolor

SOPHIA REISMANNSenior Tax Expert – Global Transfer PricingOMV

KSENIJA CIPEKHead of Tax Risk Analysis Ministry of Finance Croatia

DIRK ELBERTPartnerBDO

08:15 REGISTRATION & MORNING COFFEE

08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON09:00 Transfer Pricing, User Participation, and Attribution ofProfitstoVirtualPermanentEstablishments

• The changing environment• Case study• What will the future bring

RAFFAELE PETRUZZI Managing Director WU Transfer Pricing Center

09:30 Data security• In-house guidelines• Data Protection Directive• Exchange of information, joint audits• Providing data to third partie

BRIGITTE BAUMGARTNER Independent Transfer Pricing Expert TP Baumgartner

10:00 PANEL DISCUSSION Topic: Tax Proposals

• Common Consolidated Corporate Tax Base (CCCTB)• VAT Definitive Regime• Digital Services Tax

Moderator: LARS VON JESCHE | BDO

Panelists: CHRISTINA LEOMY-VOIGT | ATOZ Tax Advisers EMINE CONSTANTIN | TMF Group RAFFAELE PETRUZZI | WU Transfer Pricing Center

10:40 COFFEE & NETWORKING BREAK11:10 Global Mobility – Managing International Tax Risk

• Why is it important• Trends• The Bigger Tax Impact• Key considerations

PAUL DALY WOLFGANG KLOSTER Partner, Head of Transfer Pricing Partner BDO BDO AG

11:30 Exploring digital initiatives (SAF-T vs. Live Reporting)• The evolution of digitization within tax world• Challenges and benefits of digitization• Digitization trends in EMEA, APAC, and LATAM• What is next?

EMINE CONSTANTIN Global Head of Accounting & Tax TMF Group

12:00 New horizontal monitoring-programme in Austria• Co-operative procedure between taxpayer & tax administration (replaces tax audit)• Prerequisites for participation (i.e. Tax Compliance Management System)• Benefits for taxpayers & tax administrators• Lessons learned

FURHERR GEBHARD Auditor and Tax Advisor LeitnerLeitner GmbH

12:30 Compliance Risk Management: Prevention vs. Repression• Legislation and CRM System• Managing data• Prevention of Tax Fraud• Possibilities of New Technologies in Tax Administrations

KSENIJA CIPEK Head of Tax Risk Analysis Ministry of Finance Croatia, Tax Administration

13:00 INTERACTIVE LUNCH TABLE DISCUSSION Participant will be discussing pre-selected topics in small groups during lunch. Each table is assigned with a moderator to keep the discussion energetic and interesting

SUMMARY OF THE TABLE DISCUSSION Continued in the conference room, a short summary of the discussion will be shared by table moderators

14:20 International tax disputes – MAP, APAs, arbitration• Recent developments and practical cases• Challenges in negotiation• Reducing the time of resolution• Disputes involving two or more territories

EDUARDO R. FLÖRING JR. Head of Transfer Pricing Theo Müller Group

14:50 Recent developments in ICAP pilot• Current status• What are the drivers?• Covered risks• The process

MARK JOHNSON Co-Head of Unit, Tax Certainty / CbC Reporting OECD

15:30 PANEL DISCUSSION Topic: Working together – improving communication between enterprises and policymakers What are the issues facing MNEs on recent tax laws? How to improve communication between MNEs and tax administrators? Overview of globalization and market consolidation Moderator: KSENIJA CIPEK | Ministry of Finance Croatia, Tax Administration

Panelists: KATE BUSHBY | TransferWise ÓSCAR BERTRÁN | Cuatrecasas VIOLA BOGNAR | Vienna Insurance Group

16:10 COFFEE & NETWORKING BREAK

16:40 Thema Structural procedure for DEMPE analysis• DEMPE Analysis embedded in value contribution analysis• Slicing DEMPE methodological procedure• Identifying routine DEMPE contributions

YVES HERVE Managing Director NERA Economic Consulting

17:10 Building an effective tax team for the future• Evolving focus of the tax team• Tax in a mission driven start up• High performance in a hyper growth environment

KATE BUSHBY International Tax Lead TransferWise

17:40 Aligning tax KPIs/targets with the overall corporate KPIs• Are taxes managed properly?• Does Tax operate in the most efficient way possible?• Job satisfaction and recognition measures• Outsourcing compliance

MARC MOKRAB Group Head of Tax Technicolor

18:10 CHAIRPERSON’S CLOSING REMARKS, END OF DAY 1

AGENDA THURSDAY, DAY 1 #UNGCTS

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08:15 MORNING COFFEE

08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON09:00 Tax function automation

• Technology = compliance + consistency• RPA, Tax ERP, AI• Improving audit efficiency and effectiveness

STANISLAVA MANOLOVA Tax Manager PORR AG

09:30 Transformation of the TP Function• Trends regarding the digitization of the TP function• Standardization vs. Individualization• How to be prepared: process, data and personnel

ANDREAS RIEDL Partner Transfer Pricing & Head of TP Technology WTS

10:00 Fitforfuture:Arefinedapproachtotaxriskmanagement• Value chain analysis for risk monitoring and reporting• Tax controversy decision-making• Tax technology for full risk control

MARIA GRIGORYEVA Senior Manager TPA Global

10:30 COFFEE & NETWORKING BREAK11:00 Taxation of the digital economy

• How to adapt the concept of value creation to the digital environment?• Digital Services Tax (DST) and other proposals• Tackling BEPS in the digital economy• Corporate taxation of Significant Digital Presence

XAVIER CAMPS DONATA KOREN Senior Tax Manager Senior Lead of Tax Team Electronic Arts Zalando

11:30 Integrating tax technologies• Improve tax efficiency• Starbucks’s path towards a more efficient compliance process• Lessons learned

MARK HOUTZAGER EMEA Tax Leader Starbucks

12:00 The New World of Cost Contribution Agreements• Definition of Cost Contribution Agreements & Indirect Charge Method• CCAs after BEPS• The new German decree on CCAs• Changes to be implemented before 2020

DIRK ELBERT Partner BDO

12:20 Under the Microscope: Big Data and Digitalization of Tax Administrations for Audit Case Selection

• Big data• Sources of information• Current Digital landscape of tax administrators• Conclusions

LUIS CARRILLO Senior Director – Tax & Transfer Pricing Solutions Bureau Van Dijk – A Moody’s Analytics Company

12:50 NETWORKING LUNCH

13:50 TP Technology implementation• Setting a TP digitalization strategy• Effectively implementing TP technology: pitfalls & learnings• Use cases for data & analytics in TP

SOPHIA REISMANN Senior Tax Expert – Global Transfer Pricing OMV

14:20 Managing complexity in transfer pricing audit• How to reduce risk in the Transfer Pricing tax audit?• Preemptive measures to avoid a tax audit• Anti-tax audit documentation• Managing multi-country tax audits• Post-tax audit measures

XAVIER XIVILLE Partner, Lawyer, Economist Cuatrecasas ÓSCAR BERTRÁN Partner Cuatrecasas

14:50 PANEL DISCUSSION Topic: ’Addressing the Tax Challenges of the Digitalization of the Economy’ by OECD Moderator: ROSS ROBERTSON | BDO

Panelists: YVES HERVEE | NERA Economic Consulting BRIGITTE BAUMGARTNER | TP Baumgartner REINOUT DE BOER | Stibbe

15:30 COFFEE & NETWORKING BREAK

16:00 Solving Hard-to-Value Intangibles• Definition – is there any easy-to-value intangible?• BEPS-challenges: The issue of ex-post adjustments• Methodological approaches to avoid adjustments

PHILLIP DE HOMONT Associate Director NERA Economic Consulting

16:30 Management of the ETR to reduce ETR• Tax Risk monitoring• Backward and forward-looking ETR• Tax policy parameters

HARM J OORTWIJN Senior Tax Structuring, Reporting and Compliance Whirlpool

17:00 CLOSING REMARKS & CHAIRPERSON’S SUMMARY

17:10 END OF THE SUMMIT

#UNGCTS FRIDAY, DAY 2

AGENDA

UNIGLOBAL 2019 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

KSENIJA CIPEK Head of Tax Risk AnalysisMinistry of Finance Croatia, Tax Administration

Ksenija Cipek is based in Zagreb, Croatia and she is a lecturer at the local University of Law, a Member of European Law Institute, Contribute Member of the Blockchain Chamber of Commerce (US), Member of the Government Blockchain Association and Board Advisor of EUCED (European Network for Economic Cooperation and Development). Ksenija has over 20 years’ experience working at the Ministry of Finance

and the Tax Administration. She is a highly respected and recognized international tax expert who has been heavily involved in lawmaking and was responsible for many tax reforms. She participates at the Forums and working groups at the Council of the EU, the OECD and IOTA and is speaker at international conferences. As a Project Leader, she established Compliance Risk Analysis System and provided idea solution for automatic VAT return based on Risk Analysis System in Croatian Tax Administration. Ksenija is also an author and books writer.

MARK JOHNSON Co-Head of Unit, Tax Certainty / CbC Report-ing OECD

Mark in Head of Unit at the OECD Centre for Tax Policy & Administration, with responsibility for country-by-country reporting, tax risk assessment and dispute prevention, and the international compliance assurance programme (ICAP). Previously at the OECD he also had responsibility for work on tax and crime, the Forum on Harmful Tax Practices and aggressive tax planning, and he

led the work on BEPS Action 4. Prior to joining the OECD, Mark had a varied career in international tax including roles in large advisory firms, international banks and as a senior policy advisor at HM Revenue & Customs.

BRIGITTE BAUMGARTNER Independent Transfer Pricing Expert TP Baumgartner

Brigitte Baumgartner is a transfer pricing expert with a law degree in Mexico, two Masters in international tax and European tax. She has years of experience in the public and private sector and has been a member of the Joint Transfer Pricing Forum since 2015. Currently, Brigitte has started her PhD in Management, provides consultancy services in transfer pricing, and tax data protection.

XAVIER CAMPS Senior Tax ManagerElectronic Arts (EA)

Xavier is a Spanish lawyer with 15 years of international tax experience, working in practice and in-house in different EU countries and Switzerland. In his current position, Xavier is responsible for the LATAM and Southern European territories at Electronic Arts (EA) in Geneva. Formerly, he had several roles, amongst others: senior advisor at PwC and tax function leader at the Pepe Jeans Group.

UNIGLOBAL 2019 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERSBIOGRAPHIES

CHAI

RMAN

CHAI

RMAN

LARS VON JESCHE Partner, International Corporate TaxBDO

Lars von Jesche is a Partner with the International Tax Department of BDO AG in Frankfurt am Main in Germany. He has 17 years of experience in advising multinational companies in the field of transfer pricing. In addition to global transfer pricing documentation projects and the conceptual analysis and development of value chain analysis as well as transfer pricing restructuring, his consulting

expertise includes advising clients in formal tax law aspects and accompanying tax audits. After several years working for “Big 4” companies, Lars has joined BDO in 2018. His industry experience includes: Machinery and equipment; IT; Software; Network Integration; Telecoms; Automotive incl. OEMs, Tier 1-3 suppliers, commercial vehicles; Consumer; Logistics. He studied law at the Justus Liebig-University in Gießen and tax law/financial science at the University of Osnabrück with the concluding degree of LL.M. Taxation and since 2002 he bears the title specialist lawyer for tax law.

EDUARDO R. FLÖRING JR. Head of Transfer PricingTheo Müller Group

Eduardo currently leads the transfer pricing team of the Müller Group, a 6-billion EUR market-leading FMCG business headquartered in Luxembourg. He has twelve years’ experience working with TP and international tax issues, having previously trained with PwC in Brazil and Germany.

Eduardo holds an LLM from Queen Mary, University of London and has acquired the ADIT qualification

from the UK Chartered Institute of Taxation. Having joined Müller back in 2015, Eduardo has triggered various initiatives to revamp the TP management lifecycle during the BEPS project. He oversees all dispute resolution cases within the Group and is a frequent speaker in TP workshops.

RAFFAELE PETRUZZI Managing DirectorWU Transfer Pricing Center

Dr. Raffaele Petruzzi, LL.M., is the Managing Director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and an international tax advisor specializing in international corporate taxation and transfer pricing at L&P Global (Vienna, Austria) and at Ludovici Piccone & Partners (Milan, Italy). Since 2007, Raffaele has gained extensive experience in

dealing with topics related to international corporate taxation and transfer pricing, both from a professional and an academic perspective. He is a member of the United Nations Subcommittee on Article 9 (Associated enterprises: Transfer Pricing), of the International Fiscal Association (IFA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a Master of Science degree in Business Administration and Law (major: Corporate Taxation) at Bocconi University (Italy), a Master of Laws degree (LL.M.) in International Tax Law at WU, and a Ph.D. in International Business Taxation at WU.

SPEAKERS

MARC MOKRAB Global Head of TaxTechnicolor

Marc Mokrab serves as Global Head of Tax of Technicolor. He has over 13 years of experience in management of global tax departments. Prior to joining Technicolor in 2019, he spent 8 years in Geneva and London working as Head of Tax for Lagardère Sports and Entertainment (a leading global sports and entertainment agency), four years as Tax Manager of Yves Rocher (Paris) and three years as Tax consultant for various tax and

accounting firms. His main areas of specialization include tax planning, mergers and acquisitions, restructurings, the design of transfer pricing policy and related documentation, audits, dispute resolution and risk mitigation. Marc holds an MBA from Paris Business School, Master of Tax laws from the University of Paris II and a certificate in Transnational Law specialized in International and Swiss tax laws from the Law Faculty of the University of Geneva.

STANISLAVA MANOLOVA Tax ManagerPORR AG

Stanislava is a certified tax advisor and a chartered certified accountant. She had started her career with one of the Big 4 advisory firms. Currently, Stanislava holds and an in-house tax role with PORR AG – a multinational construction company based in Austria. At her current role, Stanislava is a member of the newly established Digital Finance Lab of the PORR Group and as such, is involved in several automation and digitalization initiatives.

She is keen to share her insights with us today.

HARM J OORTWIJN Senior Tax Structuring, Reporting and ComplianceWhirlpool

Harm is a Senior Tax Manager at Whirlpool EMEA, based in Pero, Italy. He has some 20 years of international tax experience with a number of multinational companies as both in-house professional and tax consulting. He graduated with honor from United Business Institutes (UBI) in Brussels with a Masters degree in Global Tax Management. Tax reporting and tax technology

as his initial core background, he has been designing and implementing global tax strategies to support the business in the changing BEPS and digitization driven tax landscape.

LUIS CARRILLO Senior Director – Tax & Transfer Pricing SolutionsBureau Van Dijk – A Moody’s Analytics Company

Luis Carrillo is Bureau van Dijk’s global director for the tax and transfer pricing market, and he is the global practice group leader for tax and transfer pricing. Luis joined Bureau van Dijk in London in 2008 as Senior Advisor. Prior to that, Luis gained over 16 years of transfer pricing advisory experience at Big 4 firms. Luis’ expertise is in the

areas of intangible valuations and global TP compliance with a focus on the high-tech and software industries.

DONATA KOREN Senior Lead of Tax TeamZalando

Donata Koren leads the Tax Team at Zalando, one of the biggest online fashion platforms in Europe. Within the role, she is responsible among others for the overall tax compliance for the group. Prior to joining Zalando in 2016, Donata worked for Big4 in the Tax Management and Accounting Services team. She advised diverse multinationals comprehensively in the field of corporate taxation, VAT and transfer pricing. Within this role, she has

gained in-depth understanding of the tax reporting process with the financial reporting framework. She is an ACCA member and a qualified tax advisor, with 13 years of tax consulting and compliance experience. Donata holds a Master of Laws degree in International Tax Law and Master of Arts degree in Ethnolinguistics.

ANDREAS RIEDL Partner Transfer Pricing & Head of TP TechnologyWTS

Mr. Riedl is a part of WTS’s Global Transfer Pricing and Valuation Practice, where he is leading the TP technology team. He specializes in operational transfer pricing and transfer pricing process planning cases as well as TP tool implementations. In that regard, he focuses on providing practical solutions to his clients that create quick wins. He frequently publishes articles on transfer pricing

developments. Mr. Riedl holds and MSc-equivalent in economics from Universitat Augsburg, Germany.

KATE BUSHBY International Tax LeadTransferWise

I have been working for TransferWise just over a year, growing the team from two to six people. TransferWise is a high growth start up and I am tasked with helping set up operations in a large number of jurisdictions worldwide, ownership of the group structure and all cross-border transactions. Before this, I worked for Dow Jones and Grant Thornton where my work was largely centered on advising Tech companies expanding into new

markets.

MARK HOUTZAGER EMEA Tax LeaderStarbucks

Mark Houtzager’s background is in supporting multinationals with managing their global indirect tax footprint. He authored an extensive portfolio of articles and other publications on VAT, and speaks frequently on conferences.

Mark joined Coopers & Lybrand in 1991, shortly after graduating from law school in Leiden, The Netherlands. He founded US VAT, Inc. in August

2010, after having spent 20 years as dedicated VAT expert at PwC and Deloitte. Mark has been living in Singapore, Connecticut and New York.

In the U.S., Mark supported multinational companies with developing new overseas business, supply chain structuring, M&A pre and post-deal structuring. A major focus was using tax technology to improve tax efficiency and reconciliations.

In July 2017, Mark joined Starbucks as their London-based EMEA Tax Leader. His focus now reaches way beyond indirect taxes, and includes “everything that is tax, and beyond”. Building a technology driven, world-class tax department in EMEA is one of Mark’s top deliverables.

UNIGLOBAL 2019 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERSBIOGRAPHIES

UNIGLOBAL 2019 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERSBIOGRAPHIES

MARIA GRIGORYEVA Senior ManagerTPA Global

Maria Grigoryeva, Senior Manager with TPA Global. TPA Global specializes in tax technology, tax and transfer pricing consulting. Maria is an expert in transfer pricing. She is leading a TPA Global’s Tax Technology projects, working closely with software providers and clients. She specializes in value chain analytics and TP/tax operating models. Maria has recently focused on the financial services, apparel, pharmaceutical and

mining industries.

SOPHIA REISMANN Senior Tax Expert – Global Transfer PricingOMV

Sophia is responsible for Global Transfer Pricing Governance within OMV Group. As part of OMV Group’s tax department, Sophia’s work covers areas such as the definition of pricing standards, intercompany commodity and financing transactions as well as transfer pricing compliance related issues. One of her main tasks is currently the digitalization of the transfer pricing function. Before joining OMV in 2015, Sophia worked at the

transfer pricing department of PwC (Austria) for over 5 years, providing a full range of services in the field of transfer pricing for clients in various industries. Sophia holds a Master in International Business from the Vienna University of Economics and Business Administration, where she specialized in international taxation.

FURHERR GEBHARD Auditor and Tax AdvisorLeitnerLeitner GmbH

Gebhard Furherr, a partner at LeitnerLeitner since 2009, is an auditor and tax advisor. After completing his studies at Vienna University of Economics and Business, he worked for the International Bureau of Fiscal Documentation (IBFD) in the Netherlands, as well as in the field of international tax law at two Big Four companies in Vienna.He advises domestic and foreign clients on issues concerning national and international tax law, more

specifically corporate and group tax law, reorganizations, M&A, and transfer pricing.Gebhard Furherr has authored a number of specialist publications and is in demand in his field as a lecturer at national and international seminars and symposiums.

EMINE CONSTANTIN Global Head of Accounting & TaxTMF Group

Emine is EMEA Head of Accounting & Tax. Prior to her present role within the TMF Group, Emine was Managing Director of the TMF organization in Romania leading the local practice comprised of over 100 professionals. Emine has more than 20 years of international experience in the accounting & tax area and has been involved in setting up the outsourcing model for a number of international clients in various industry fields, such as

pharmaceuticals, oil & gas, real estate. She holds a Business Administration Diploma from the University of Bucharest. She is also member of local accounting and tax professional organizations and a fellow member of ACCA (Association of Chartered Certified Accountants). Emine is also a qualified CFA (Chartered Financial Analyst).

PHILIP DE HOMONT Associate DirectorNERA Economic Consulting

Mr. de Homont is an expert in NERA’s global Transfer Pricing practice, where he provides transfer pricing advice to international corporations and law firms. He specializes in the transfer pricing of in tax audits and litigation cases, as well as transfer pricing in the digital economy.Mr. de Homont has extensive experience in the defense of licensing and valuation arrangements for intangibles. His recent cases covered transactions

from brand licenses, profit splits for local distribution and sales companies, to the valuation of user data and relocations of functions. In the digital economy, he has introduced novel approaches to separate market and user intangibles from technical engineering and established methods to value platform intangibles.

YVES HERVE Managing DirectorNERA Economic Consulting

Dr. Yves Hervé is a Managing Director in NERA’s Global Transfer Pricing Practice and is operating in NERA’s Frankfurt office. Dr. Hervé has been a fully dedicated TP professional since 1999. Prior to joining NERA, he was a Transfer Pricing Partner at one of the Big Four accounting firms, then the German Tax Leader of the global Value Chain & Digital Transformation practice at another Big Four firm. In the course of his projects and as

responsible promoter of broader solution platforms, Dr. Hervé has been particularly active in designing innovative solutions for Value Chain Analysis (e.g., a solution approach to rank functional value contributions in a non-distortionary manner, as well as a peer group based analytical approach), Risk Economics (e.g. quantification and risk adjustments solutions for business restructurings and hybrid value functions), Profit Splits (e.g. solutions based on relative bargaining power), and TP and tax impact simulation. Dr. Hervé has provided expert opinion reports in relation to European tax audits and has assisted clients with economic analysis for advance pricing agreements with local authorities. In litigation, he has been involved in cases considering intellectual property remuneration, related tax exit charges, and their underlying business valuations. He has also provided the economic analysis for international arbitrations.

DIRK ELBERT PartnerBDO

Dr. Dirk Elbert is a Partner with the International Tax Competence Center of BDO AG in Germany. He is a member of the executive committee of the Corporate International Tax Centre of Excellence of the BDO network and the international tax working party of the Institute of Public Auditors in Germany (IDW).Dirk has been working in taxation since 1996. He specializes in transfer pricing and cross-border

tax planning. Dirk regularly speaks at seminars about a range of tax and legal issues, particularly transfer pricing, and he is co-author of the leading German transfer pricing commentary “Verrechnungspreise” published by C.H.Beck. Dirk joined BDO AG in 2005, after several years as a tax officer with the German tax authorities, as a consultant with a number of law firms and as an assistant at the Institute of Finance and Tax Law of the University in Heidelberg. He studied finance at the University of Applied Sciences in Ludwigsburg and law at the Law School of the University in Heidelberg; Dirk is a Doctor of Jurisprudence.

UNIGLOBAL 2019 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERSBIOGRAPHIES

PAUL DALY Partner, Head of Transfer PricingBDO UK LLP

Paul is a UK tax partner specializing in transfer pricing and international tax. He assists clients with transfer pricing studies and documentation exercises, design and implementation of value chain tax structures as well as dealing with HMRC and tax authorities internationally on inquiries and disputes, including supporting on MAPs and APAs. Paul assists clients on a range of international tax issues alongside transfer pricing including business

restructuring pricing, permanent establishment profit attribution, R&D tax reliefs and intellectual property tax incentives.He works closely with his clients across a range of assignments from supporting those taking first steps in establishing overseas operations, through to helping global businesses outsource their worldwide transfer pricing compliance. He has in-house experience and perspective from time in a transfer pricing role within a FTSE100 business and understands the importance of providing grounded, practical advice.

WOLFGANG KLOSTER PartnerBDO AG Wirtschaftsprüfungsgesellschaft

Wolfgang Kloster started to work with BDO January 1991. Over the years, he became a specialist in the taxation of individuals.Since 2000, he is the Head of the Centre of Excellence “Payroll and Global Expatriate Services” which is located in Berlin and Frankfurt.Beside his broad experience in expatriate tax services his other areas of competencies include

payroll accounting, social security contribution, occupational pension scheme and innovative remuneration (e.g. stock options, benefit in kind). Wolfgang holds lectures and seminars for our clients regarding current developments in the wage tax law.Since 2008, he is Member of the “Global Expatriate Services” of BDO International.

XAVIER XIVILLE Partner, Lawyer, EconomistCuatrecasas

Tax partner in the law firm Cuatrecasas in its Barcelona office. Broad experience in international tax advice, restructurings, tax audits and MAPs.

ÓSCAR BERTRÁN Partner Cuatrecasas

Tax partner in the law firm Cuatrecasas in its Barcelona office. More than 15 years’ experience in tax audits and 13 years’ experience in transfer pricing, APAs and tax rulings.

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12th Global Banking Innovation Forum & EXPO23 & 24 April 2020, Prague, Czech Republic

The 12th Global Banking Innovation Forum & EXPO is a must-attend event for bankers from all over the world, with a strong educational program based on leading banks case studies, various networking opportunities: formal and informal, and a great EXPO hall with world’s most innovative existing FinTech solutions to date.In today’s demanding market situation, it is not only necessary for banks to comply, but also to retool and transform, to be innovative, new and fresh, in order to win the customer of the future. The Forum will uncover the newest trends in banking, the most innovative and effective strategies for improving customer experience and optimizing internal banking processes. It will offer its participants various solutions for reinforcing the position of banks in the financial services sector.Join us and 500+ brightest minds of banking industry to discuss and shape the future of financial sector in the heart of Europe on 23rd & 24th of April 2020.

UPCOMING EVENTS

www.nera.com/tp

Contacts

Dr. Yves HervéManaging Director+49 69 710 447 508 yves.herve@nera.com

Economic experts.Unmatched experience. Worldwide.

Philip de HomontAssociate Director+49 69 710 447 502philip.de.homont@nera.com

NERA’s Services in Transfer Pricing• Dispute Resolution and Economic Litigation Support• Value Contribution and DEMPE Analysis• Intangibles and Risk Pricing• Business Restructuring and Digital Transformation

INTERACTIVE LUNCH TABLE DISCUSSIONS

Table 1DAC6Moderator: RICHARD WELLMANN | BDO

Table 2How ready are you for the 2021 VAT changes?Moderator: EMINE CONSTANTIN | TMF Group

Table 3Guidance on the transfer pricing of intangiblesModerator: XAVIER XIVILLE | Cuatrecasas

Table 4The Role and Development of Advance Pricing Agreement (APA)andBindingRulingsinthefieldofTransferpricingModerator: KSENIJA CIPEK | Ministry of Finance Croatia, Tax Administration

Table 5Transfer Pricing Litigation: Experiences of Going to CourtModerator: PHILIP DE HOMONT | NERA Economic Consulting

Table 6Defending TNMM solutions in a world of decentralized intangible DEMPE contributionsModerator: YVES HERVE | NERA Economic Consulting

Table 7Cooperative compliance initiatives in the countries of the participants (from Horizontal Monitoring, SAF-T to the ICAP pilot)Moderator: FURHERR GEBHARD | LeitnerLeitner GmbH

Table 8Quick wins when digitalizing the TP function of an MNEModerator: ANDREAS RIEDL | WTS

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We would like to thank everyone who assisted with the research and organisation of this event, particularly the speakers for their support and commitment and we thank all of our sponsors and delegates and we hope to see you in one of our future events as well.