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25-26 October 2018 Berlin, Germany TITANIC Gendarmenmarkt Berlin SPEAKERS Debra Evans Advisor, International Co-operation and Tax Administration Division OECD, France Dr. Raffaele Petruzzi Managing Director WU Transfer Pricing Centre, Austria Andrea Lee Head of Group Project and Group Cost Controlling and TP Erste Group Bank AG, Austria Andrei Belinski Head of International Tax Centrica, UK Stanislava Manolova Tax Manager PORR AG, Austria Philip de Homont Associate Director NERA Economic Consulting Donata Koreń Lead International Tax & Transfer Pricing Zalando SE, Germany Maria Grigoryeva Senior Associate TPA Global, The Netherlands Ivan Dimitrov Group Tax Strategy, Transfer Pricing Deutsche Post DHL Group, Germany Roderick Sayers Independent Tax Expert Dr. Adolf Poindl Head of Group Tax MEGATECH Industries GmbH, Austria Emmanuel Llinares Managing Director – Chair of the Global TP Practice NERA Economic Consulting Andreas Riedl Director, Transfer Pricing WTS, Germany Harm J. Oortwijn Senior Manager, Tax Whirlpool Corporation, Italy Xavier Camps Senior Tax Manager Electronic Arts, Switzerland Dr. Yves Hervé Managing Director NERA Economic Consulting Dr. Jochen Bahns Partner Lawyer, Tax Consultant Flick Gocke Schaumburg Partnerschaft mbB Mathilde Ostertag Partner GSK Stockmann, Luxembourg Hema Khurana Director Transfer Pricing & Tax Management Consulting Deloitte, The Netherlands Luis Carrillo Director – Tax & Transfer Pricing Solutions Bureau van Dijk – A Moody’s Analytics Company Dr. Clemens Nowotny Partner LeitnerLeitner Xavier Xivillé Partner Cuatrecasas, Gonçalves Pereira, S.L.P., Spain Aleksandra Jaszczuk Director of Transfer Pricing Moore Stephens Central Audit Sp. z o.o., Poland Yang Yan Manager US Tax Desk Baker Tilly Steuerberatungsgesellschaft mbH Dr. Mathias Hildebrandt Head of Tax Zalando SE, Germany UNIGLOBAL 2018 www.uni-global.eu tel. +420 226 220 400 fax +420 226 220 444 CHAIRMAN Charalambos Antoniou Director, Tax and Legal Services PwC, Switzerland 5 th ANNUAL CORPORATE TAX SUMMIT Gold Sponsor Badges Sponsor Bronze Sponsors Silver Sponsors

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Page 1: th CORPORATE TAX SUMMIT › wp-content › uploads › 2020 › 01 › Programme... · 2020-01-10 · • Tax audit challenges to be expected five years from now Dr. Yves Hervé 10:10

25-26 October 2018Berlin, Germany

TITANIC Gendarmenmarkt Berlin

SPEA

KERS

Debra Evans Advisor, International Co-operation and Tax Administration Division OECD, France

Dr. Raffaele Petruzzi Managing DirectorWU Transfer Pricing Centre, Austria

Andrea LeeHead of Group Project and Group Cost Controlling and TPErste Group Bank AG, Austria

Andrei BelinskiHead of International TaxCentrica, UK

Stanislava ManolovaTax ManagerPORR AG, Austria

Philip de HomontAssociate DirectorNERA Economic Consulting

Donata KoreńLead International Tax & Transfer PricingZalando SE, Germany

Maria GrigoryevaSenior AssociateTPA Global, The Netherlands

Ivan DimitrovGroup Tax Strategy, Transfer PricingDeutsche Post DHL Group, Germany

Roderick SayersIndependent Tax Expert

Dr. Adolf PoindlHead of Group TaxMEGATECH Industries GmbH, Austria

Emmanuel LlinaresManaging Director – Chair of the Global TP PracticeNERA Economic Consulting

Andreas RiedlDirector, Transfer PricingWTS, Germany

Harm J. OortwijnSenior Manager, TaxWhirlpool Corporation, Italy

Xavier CampsSenior Tax ManagerElectronic Arts, Switzerland

Dr. Yves HervéManaging DirectorNERA Economic Consulting

Dr. Jochen BahnsPartner Lawyer, Tax ConsultantFlick Gocke Schaumburg Partnerschaft mbB

Mathilde OstertagPartnerGSK Stockmann, Luxembourg

Hema KhuranaDirector Transfer Pricing & Tax Management ConsultingDeloitte, The Netherlands

Luis CarrilloDirector – Tax & Transfer Pricing SolutionsBureau van Dijk – A Moody’s Analytics Company

Dr. Clemens NowotnyPartnerLeitnerLeitner

Xavier XivilléPartnerCuatrecasas, Gonçalves Pereira, S.L.P., Spain

Aleksandra JaszczukDirector of Transfer PricingMoore Stephens Central Audit Sp. z o.o., Poland

Yang YanManager US Tax DeskBaker Tilly Steuerberatungsgesellschaft mbH

Dr. Mathias HildebrandtHead of TaxZalando SE, Germany

UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

CHAI

RMAN Charalambos Antoniou

Director, Tax and Legal Services PwC, Switzerland

5th ANNUAL

CORPORATE TAX SUMMIT

Gold Sponsor Badges SponsorBronze SponsorsSilver Sponsors

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08:30 Registration & morning coffee

08:45 Welcome & opening remarks from the chairman

OPENING & KEYNOTE ADDRESSRECENT DEVELOPMENTS IN CORPORATE TAX

09:00 Transfer Pricing and Financial Transactions• Stand-alone rating vs implicit support• Benchmarking – tips and tricks• Are bank loans really comparable transactions

Andrea Lee Head of Group Project and Group Cost Controlling and TP Erste Group Bank AG, Austria09:35 CbC, ICAP and the Global Tax Certainty Agenda

• CbC: First experiences on CbC and initial results, compliance and implementation of Action 13• International Compliance Assurance Program: Status of ICAP• Tax Certainty Agenda: Wider initiatives such as better access to MAP, MAP status, arbitration, APA programmes

Debra Evans Advisor, International Co-operation and Tax Administration Division OECD, France

10:10 Pricing Intra-group Financial Transactions for Compliance with Transfer Pricing Regulations

• Application of the CUP method using Loan Agreement data• Comparability adjustments based on credit risk models• Arriving at an Arm’s Length return on risk

Luis Carrillo Director – Tax & Transfer Pricing Solutions Bureau van Dijk – A Moody’s Analytics Company

10:45 – 11:15 Morning coffee & networking break

11:15 Tax Transparency Landscape• External Tax Transparency• Internal Tax Transparency• Build a tax communication strategy• Being a Tax Transparent Organization – Pros and Cons

Charalambos Antoniou Director, Tax and Legal Services PwC, Switzerland11:50 Permanent Establishment Risks for a Multinational Group – a 2018 view

• New landscape - BEPS recommendations and MLI• Old issues in the new environment

• High mobility workforce• Operating a global matrix structure

• New issues• Quest to tax value – digital PEs• Lower PE threshold – “trading with” and “trading (with)in” the country

• PE risk assessment• PE risk management

Andrei Belinski Head of International Tax Centrica, UK

12:25 – 13:25 Networking lunch

TECHNOLOGICAL DEVELOPMENTS IN CORPORATE TAX13:25 Taxation of the Digital Economy

• Digital economy. Tax challenges • After BEPS scenario: Legislative proposals. Nexus redefinition• Alternative solutions. Personal point of view

Xavier Camps Senior Tax Manager Electronic Arts, Switzerland

13:55 Operational Transfer Pricing – What, Why and How?• Key elements of operational transfer pricing• Requirements & challenges• Why is it important?• Solution directions

Hema Khurana Director Transfer Pricing & International Tax Deloitte, The Netherlands

14:25 Tax Audit Management and the Future of Cooperative Compliance

• Underscoring the need for automation of audit processes• Centralising audit documentation• Creating a standard, organized approach• Automation and efficiency• Mutual agreement procedures in managing disputes

Dr. Adolf Poindl Head of Group Tax MEGATECH Industries GmbH, Austria

14:55 Centralisation of the Corporate Tax Function• Developing centres of excellence• Spotlighting the provision of service• The need for shared trust between entities (corporation, shared service centre & the tax department)• Maximising efficiency• A focus on the security of sensitive data

Harm J. Oortwijn Senior Manager, Tax Whirlpool Corporation, Italy

15:20 – 15:50 Afternoon coffee & networking break

15:50 Valuation and financing in cases of business restructurings• Growing incentives to restructure (e.g. Brexit, US Tax Reform, Digitization)• Best practice valuation methodology • The role of intercompany transactions and other tax effects within the valuation process• How to finance a acquisition / merger / restructuring (and to determine an arm’s length interest rate)

Andreas Riedl Director, Transfer Pricing WTS, Germany

16:25 Transfer pricing in the digital economy: value of users and economic ownership of valuable IP

• What is the value of user data in the digital economy• What are value drivers / valuable IP associated generated user data• From “value chain” to “value network”

Philip de Homont Associate Director NERA Economic Consulting

16:50 New approach to Financial Transactions in BEPS realms• How BEPS impact standard financial transactions: loans, guarantees, cashpooling, bonds, factoring , leasing etc.• Benchmarking financial transactions – issues and solutions• Risk of ignorance of financial instruments used in standard transactions: hedging, securitisation, derivatives.• BEPS limitations and areas for interpretation when setting-up intercompany financial transactions

Aleksandra Jaszczuk Director of Transfer Pricing Moore Stephens Central Audit Sp. z o.o., Poland

17:25 Closing remarks from the Chairman17:30 Cocktail reception and after conference networking

Thursday - 25 October 2018 DAY 1

UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

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14:20 Exchange of Information: where do we stand?• Status of the existing EOI regulations and ECJ cases• Update on the exchange of tax rulings and advanced pricing agreements• The tax intermediaries directive implementing the mandatory disclosure of cross-border tax planning structures (DAC 6)• OECD mandatory disclosure rules for CRS avoidance arrangements and opaque structures

Mathilde Ostertag Partner GSK Stockmann, Luxembourg

14:50 Taxation of IP & Hard-to-Value Intangibles Post BEPS• Developments in taxation for IP & HTVI • Overcoming uncertainty surrounding taxation of IP• Ownership of IP (principal vs. network model)• Withholding tax and compliance considerations of IP ownership structures

Ivan Dimitrov Group Tax Strategy, Transfer Pricing Deutsche Post DHL Group, Germany

15:25 Future TP Challenges of Digital Transformation• Digital Transformation will massively transform economic contributions in existing value chains• How transfer pricing analysis will have to be amended to a changing world• Tax audit challenges to be expected five years from now

Dr. Yves Hervé Managing Director NERA Economic Consulting

15:50 – 16:20 Coffee & networking break

16:20 Highlights of the 2017 US tax reform for businesses• General changes in the US federal corporate taxation• Impacts on US MNEs: new territorial tax system, GILTI and FDII• BEAT and anti-hybrid rules for related party transactions• New provisions for pass-through entities

Yang Yan Manager US Tax Desk Baker Tilly Steuerberatungsgesellschaft mbH

16:50 PANEL DISCUSSION: What does the future look like for tax in the following areas: Tax Technology, Transfer Pricing, Tax Transparency

• Key points discussed during the event Moderated by: Roderick Sayers Independent Tax Expert Panelists: Emmanuel Llinares Managing Director – Chair of the Global TP Practice NERA Economic Consulting Charalambos Antoniou Director, Tax and Legal Services PwC, Switzerland Dr. Mathias Hildebrandt Head of Tax Zalando SE., Germany Luis Carrillo Director – Tax & Transfer Pricing Solutions Bureau van Dijk – A Moody’s Analytics Company Daniela Steierberg Head of Group Tax Medac GmbH, Germany

17:25 Closing remarks & chairman’s summary. Closing of the conference

Friday - 26 October 2018DAY 2

08:30 Re-registration & morning coffee

08:45 Welcome & opening remarks from the chairman

OPENING ADDRESSAUTOMATING TAX FUNCTIONS

09:00 Automation and the Changing Role of Tax Executives• Working effectively with technology• Data science, analytics and the evolving skillset• Soft skills and interaction with other business functions• Meeting the increasing requirements of the tax function• Leadership and the future tax professional

Stanislava Manolova Tax Manager PORR AG, Austria

09:35 Real-Time Tax Data Sharing and Analytics Automation• Adoption of real-time information sharing systems – country examples• Tax data analytics automation – country examples• Internal tax data warehouse – practical tips• Preparation for detailed data sharing – dos and don’ts

Maria Grigoryeva Senior Associate TPA Global, The Netherlands

10:10 Digitalisation of Business Models and Transfer Pricing: The New Frontier of Business Restructurings?

• Digitalisation of traditional business models• Arm’s length nature of business restructuring• What will the future bring?

Dr. Raffaele Petruzzi Managing Director WU Transfer Pricing Centre

10:45 – 11:25 Coffee & networking break

11:25 Recent Developments in BEPS Implementation• Approaches adopted by member jurisdictions• Peer reviews and dispute resolution• Reportable cross-border arrangements• Optimisation of CbC reporting

Donata Koreń Lead International Tax & Transfer Pricing Zalando SE, Germany

THE FUTURE OF CORPORATE TAX FUNCTIONS12:00 Future Developments in Corporate Tax

• Development of corporate tax revenue in the EU• Pushing for fundamental reform of international tax rules• Taxing profits in the digital economy• Common Consolidated Corporate Tax Base• Providing a fair framework for taxing all businesses in the future

Xavier Xivillé Partner Cuatrecasas, Gonçalves Pereira, S.L.P., Spain 12:25 MAPs and APAs – Recent developments and practical cases

• Update on current initiatives• EU-Directive on tax dispute resolution mechanism• Procedural aspects of the various instruments

Dr. Clemens Nowotny Partner LeitnerLeitner & Dr. Jochen Bahns Partner Lawyer, Tax Consultant Flick Gocke Schaumburg Partnerschaft mbB

13:00 – 14:10 Strategic interactive lunch Interactive lunch, where participants will be discussing pre-selected topics in small groups, with the contribution of a table moderator to make the discussions more energetic

UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

Short URL: www.uni-global.eu/tax18 Password has been sent to your email address.

PDF Presentations

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UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERS

CHAI

RMAN

SPEAKERS

Charalambos Antoniou Director, Tax and Legal ServicesPwC, Switzerland

Harry is an ACCA, ADIT qualified tax professional with over fourteen years tax experience in the Banking and Insurance sectors. Harry recently joined PwC Switzerland as a Director, Tax and Legal Services. He is the Tax Function Design Leader and supports FS and non-FS clients increasing efficiency and effectiveness of operations in reaching their tax strategic goals. Harry also supports clients in preparing and/or

updating their tax governance frameworks (i.e. tax strategy, tax risk framework, tax transparency, tax leadership framework, etc.). Further, Harry advises FS clients on mergers & acquisitions (from due diligence phase to integration or separation) and other restructuring transactions as well as on tax accounting topics. Before joining PwC, Harry headed up the Tax Operations, Transformation and Risk Management function in Zurich’s Insurance Group and he was leading the tax work-stream for global M&A transactions. Previously, he headed Zurich’s Tax Accounting and Reporting function. He is also a freelancer part-time lecturer for ACCA and ADIT papers.

Andrea Lee Head of Group Project and Group Cost Controlling and TPErste Group Bank AG, Austria

Andrea is originally from the Czech Republic, where she studied at the University of Economics, followed by postgraduate study in international taxation in Vienna. She spent the first nearly 15 years in the consulting industry, working for Horwath TPA and Deloitte around the world; including places like Shanghai, Ho Chi Minh City and Brussels. Andrea specializes in the transfer

pricing of financial transactions. Thus, when the opportunity presented itself in 2014, she joined Erste Bank as head of TP. Since then she has held different roles, currently group cost and project controlling but maintaining the responsibility for TP.

Harm J. OortwijnSenior Manager, TaxWhirlpool Corporation, ItalyHarm is Senior Tax Manager at Whirlpool Corporation based out of Italy. He has over 20 years of international tax experience with multinational companies as both in-house professional and tax Consultant. He graduated with honors from (UBI) United Business Institutes in Brussels with a Master degree in Global Tax Management.

Hema KhuranaDirector Transfer Pricing & Tax Management ConsultingDeloitte, The Netherlands

Hema Khurana is a Director within the Tax Management Consulting team of Deloitte Netherlands. She has over 16 years of Global Transfer Pricing experience with a blend of consulting and in-house tax roles within reputed multinational companies.

Hema has been leading various Operational Transfer Pricing projects including Finance and

Tax Transformation as well as Business Restructuring projects for major multinational companies. She has extensive experience in designing and implementation of various operating models for client across industries and working closely with Finance, Supply chain and Technology experts. Hema’s core focus is optimizing intercompany processes and implementation of various technology solutions at clients (such Longview and others). Hema is a certified chartered accountant from India.

Dr. Raffaele PetruzziManaging DirectorWU Transfer Pricing Centre, Austria

Dr. Raffaele Petruzzi, LL.M. is 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 - Ludovici Piccone & Partners.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. From the professional perspective, Raffaele has gained relevant experience in advising clients on specific topics (e.g. international tax issues and transfer pricing issues related to services, permanent establishments, financing, business restructuring, intangibles, and indirect taxes), international tax and transfer pricing risk management and compliance, drafting and reviewing intra-group agreements, and optimising international tax structures. From the academic perspective, he is a frequent speaker in international conferences and lecturer of numerous courses (amongst others, in Brazil, Bulgaria, China, Cyprus, France, Germany, Italy, the Netherlands, Poland, Romania, Serbia, Singapore, and Spain), as well as author of many publications on international tax and transfer pricing topics. Moreover, Raffaele regularly cooperates with professionals in advisory, the business community, governments and international organizations (e.g. OECD, United Nations, World Bank Group, European Union). Finally, Raffaele 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.

Andrei BelinskiHead of International TaxCentrica, UK

Andrei Belinski is Head of International Tax at Centrica plc., an energy and services company. He has been practicing international tax for over 25 years in several jurisdictions working for accountancy firms and large multinationals and specialises in tax issues arising from cross-border investments, treasury activities and transfer pricing.

Stanislava ManolovaTax ManagerPORR AG, Austria

Stanislava is a certified tax advisor and a chartered certified accountant and started her career with one of the Big 4 advisory firms. Currently Stanislava holds an in-house tax role with PORR AG – a multinational construction company based in Austria. In her current role Stanislava has had the opportunity to work on a couple of digitalisation projects and is very keen to share her insights with us.

Ivan DimitrovGroup Tax Strategy, Transfer PricingDeutsche Post DHL Group, Germany

Ivan’s journey into the world of transfer pricing and international tax advisory started more than 10 years ago. During that time he supported clients of various sizes and locations in the field of international (direct and indirect) taxation. In 2017 Ivan decided to dedicate himself not only to developing, documenting and defending tax strategies but also to implementing them into the business processes and found an ideal place for this in the Transfer

Pricing Team of Deutsche Post DHL.

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UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

SPEAKERS

Dr. Adolf PoindlHead of Group TaxMEGATECH Industries GmbH, Austria

Adolf is a graduate of the Vienna School of Business Administration, where he studied Commercial Science. He is a Certified Tax Advisor with more than 25 years of experience in all fields of national and international tax matters, with special focus on group tax planning, PE structures, mergers & acquisitions, corporate reorganisations and restructurings.

Adolf has been the Head of Tax of MEGATECH Group since 1 September 2016.

Debra EvansAdvisor, International Co-operation and Tax Administration DivisionOECD, France

Debra has a Masters Degree in Tax Policy gained during her 17 years of experience in HMRC, the UK tax authority, latterly as a Competent Authority with responsibility for CbC implementation and HMRC’s participation in the ICAP pilot process. Debra recently joined the OECD as an advisor on BEPS actions with specific focus on her experience on the implementation of Action 13, Country by Country

Reporting.

Maria GrigoryevaSenior AssociateTPA Global, The Netherlands

Maria Grigoryeva, Senior Associate with TPA Global.

Maria is an expert in transfer pricing. She is leading 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.

Dr. Yves HervéManaging 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.

In the course of his professional career, Dr. Hervé has covered all major TP consulting issues for global clients, from integrated value chain structuring and TP planning to global TP compliance issues and documentation, TP economic solution design, IP

valuation, cost contribution solutions, business restructurings, tax audit defense and dispute resolution. His client portfolio covers global multinationals across a broad segment of industries (in particular life sciences, chemical & industrial products, transportation & logistics, automotive, energy, consumer, high-tech).

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.

Philip de HomontAssociate DirectorNERA Economic Consulting

Mr. de Homont is part of NERA’s Global Transfer Pricing and Intellectual Property Practices, where he provides planning and litigation advice to international corporations and law firms. Mr. de Homont specializes in the defense of complex and unusual transfer pricing and intellectual property cases. Mr. de Homont has extensive experience in the valuation of financial products and unique intellectual property in a variety of industries,

including the pharmaceuticals, telecommunication, consumer goods, banking, and energy industries. He has defended corporate charges, brand and other intellectual property royalties, the valuation of companies or business activities, and complex financial contracts, in particular option-like contracts. Mr. de Homont frequently publishes articles on transfer pricing developments, and on defense and planning cases. He is co-author to two leading German textbooks, on Transfer Pricing and Intellectual Property respectively. Mr. de Homont holds an MSc in economics from the University of Warwick, and an MSc-equivalent in physics from the Technische Universität München.

Dr. Clemens NowotnyPartnerLeitnerLeitner

Clemens Nowotny specializes in taking care of domestic and foreign companies in all matters concerning Austrian or international tax law. His specialties include in particular supporting foreign investors making inbound investments into CEE/SEE countries, group tax planning, issues associated with establishing PEs and PE profit allocation, as well as withholding tax and the taxation of international artists and athletes. Furthermore,

he counts as one of Austria’s leading experts on transfer pricing and is listed as an acknowledged specialist in “World Transfer Pricing” and the “Expert Guide to the World’s Leading Transfer Pricing Advisers”. Clemens Nowotny regularly provides advice on the structuring and implementation of transfer pricing models, the defence of transfer pricing systems in tax auditing procedures, the collection of binding rules, the resolution of international transfer pricing disputes, and the preparation of transfer pricing documentation and benchmarking analyses. He is in demand as a speaker, both in Austria and abroad, on issues related to his areas of expertise, and his opinions on topics connected with transfer pricing are regularly published (“Verrechnungspreisrichtlinien – Praxiskommentar” [Transfer Pricing Guidelines – Practical Commentary]). Clemens Nowotny is a tax advisor and has been a partner at LeitnerLeitner since 2008.

Dr. Jochen BahnsPartner Lawyer, Tax ConsultantFlick Gocke Schaumburg Partnerschaft mbB

Jochen Bahns is a lawyer and tax consultant at the Bonn office of FGS. He advises multinational corporate groups on all areas of German and international tax law, in particular M&A, corporate reorganizations and the structuring of inbound and outbound investments. His practice also covers tax audits, litigation and transfer pricing proceedings. Jochen Bahns is a frequent speaker and author on topics relating to international taxation at national

and international seminars and a guest lecturer at the German Federal Finance Academy.

Donata KoreńLead International Tax & Transfer PricingZalando SE, Germany

Donata Koren has 12 years of tax consulting and compliance experience, advising multinationals comprehensively in the field of corporate taxation, VAT and transfer pricing. She had worked for Big4 before she joined Zalando’s in-house tax team in 2016. Donata holds tax advisor certificate and ACCA membership title.

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Andreas RiedlDirector, Transfer PricingWTS, Germany

Mr. Riedl is part of wts’s Global Transfer Pricing and Valuation Practice, where he provides planning, documentation and litigation advice to international corporations. He specializes in operational transfer pricing and transfer pricing process planning cases. In that regard, he focusses on the availability and analysis of internal data relevant for transfer pricing and the implementation of transfer pricing technology solutions. He frequently publishes

articles on transfer pricing developments. Mr. Riedl holds an MSc-equivalent in economics from the Universität Augsburg, Germany.

Xavier XivilléPartnerCuatrecasas, Gonçalves Pereira, S.L.P., Spain

Mr. Xivillé has extensive experience in advising national and international groups, as well as in business restructurings and international investment planning. He is an expert in international tax.

His expertise also includes advising family offices on tax matters.

Mr. Xivillé speaks regularly at seminars and conferences on international tax and has published

several articles in specialized Spanish press. He lectures at prestigious business schools, including in the Master’s Degree in Laws in Taxation and the Master’s Degree in Venture Capital and Private Equity, both at Universitat International de Catalunya (UIC). He is a member of the Barcelona Bar Association and the Catalan Association of Economists.

Luis CarrilloDirector – 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.

Aleksandra JaszczukDirector of Transfer PricingMoore Stephens Central Audit Sp. z o.o., Poland

Aleksandra Jaszczuk - International Transfer Pricing Expert and Senior Business Advisor and has over 15 years of work experience in the area of transfer pricing, controlling, audit and internal control including 4 years in the BIG 4 environment comprising: 9 years as transfer pricing expert. Currently she is: the Director of Transfer Pricing and Global Expert in Benchmarking Financial

Transactions with Moore Stephens, trainer with Warsaw School of Economics (incl. post diploma studies for Polish Tax Authorities), 5 years as Global Transfer Pricing Manager and Group Business Controller for a leading Nordic NASDAQ quoted wholesale group (Solar A/S), and Aurora Group. She also have managed several transfer pricing tax audits across Europe and worked over 6 years as business advisor and business controller.

Aleksandra is a graduate of the University of Lodz, Masters in Economics – Banking and Finance faculty -specialization: Finance Management, Lodz, Poland. Aleksandra completed her MBA with INE PAN in Warsaw. Her final MBA project was quoted in Economic Bulletin published by the Polish Economic Society. Apart from her native Polish, Aleksandra is fluent in English and can communicates in French and German.

Mathilde OstertagPartnerGSK Stockmann, Luxembourg

Mathilde Ostertag heads the tax practice at the law firm GSK Luxembourg SA.

She is a qualified lawyer and a licensed specialist for tax law. Mathilde advises on international tax planning with a focus on inbound investments in the EU. She provides tax structuring of private equity funds, real estate investments, M&A, structured finance and intellectual property transactions.

Prior to joining GSK Luxembourg, Mathilde has worked for a magic circle and a Benelux law firm for the past 10 years.

Mathilde is a member of the International Fiscal Association and publishes regularly on EU tax law topics. She is fluent in English, French, German and Portuguese.

Xavier CampsSenior Tax ManagerElectronic Arts, Switzerland

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.

Yang YanManager US Tax DeskBaker Tilly Steuerberatungsgesellschaft mbH

Yang Yan has over 6 years of professional experience in the US tax practice. She advises US inbound and outbound clients on US tax compliance and planning, in particular on determination and taxation of CFCs and PFICs, investment analysis such as in US real estate and PE funds, structuring of business groups involving US parents and/or subsidiaries. The services she provides also cover various FATCA related topics, entity classification

election and application of US income tax treaties. Her clients range from corporations and partnerships in financial service sector and various industrial businesses to high net-worth individuals.

Prior to joining Baker Tilly, Yang has worked for KPMG and EY. She is a US CPA and Enrolled Agent (tax practitioner).

SPEAKERS

UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

Sli.do Interactive Q&A platform

Event code:#UNGTAX

The hashtag is used also for twitter, linkedin and other social media

Laman Abdullayeva, Production Manager tel. +420 226 220 412email: [email protected]

Jana Malysheva, Event Manager tel. +420 226 220 420email: [email protected]

www.slido.com

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UNIGLOBAL 2018 www.uni-global.eutel. +420 226 220 400 fax +420 226 220 444

Silver Sponsors

Bronze Sponsors

NERA Economic Consulting is a global firm of experts dedicated to applying economic, finance, and quantitative principles to complex business and legal challenges. For over half a century, NERA’s economists have been creating strategies, studies, reports, expert testimony, and policy recommendations for government authorities and the world’s leading law firms and corporations. We bring academic rigor, objectivity, and real world industry experience to bear on issues arising from transfer pricing, competition, and finance.

Our Global Transfer Pricing Practice offers a full range of transfer pricing services, independent advice, and valuation support by world-class economists. Our direct, hands-on approach to transfer pricing enables us to develop higher quality products, and to collaborate more effectively with our clients. All 100 of the American Lawyer Global 100 largest law firms from around the world have engaged us to create valuable and sustainable solutions for their multinational corporate clients and as experts in litigation and arbitration. Clients range from some of the largest and best known companies in the world to midsize companies, and include 96 of the Fortune 100 largest corporations.

For more information on NERA Economic Consulting please visit www.nera.com

Longview makes enterprise software that drives competitive advantages for Finance and Tax teams in the NOW business reality.

Longview provides a suite of best of breed tax solutions that leverages more than 20 years of innovation and experience in areas of data collection, computation, reporting and analytics to help you:

• Eliminate the burden of data gathering and validation

• Clear the way for strategic thinking and action

• Elevate your Tax function into a strategic business asset

Thousands of tax professionals around the globe leverage Longview to make strategic and immediate business decisions every day, with confidence.

Visit longview.com/tax to find out more about our tax solutions and request a demo.

With 1,000 lawyers, Cuatrecasas is a law firm present in 12 countries. We advise on all areas of business law, applying a sectoral approach and covering all types of business. We have 16 offices on the Iberian Peninsula and 11 international offices. We represent companies that are leaders in their sectors, advising them on their investments in the major markets. In 2018, we have been considered the “Most innovative firm (outside UK)” in the FT Innovative Lawyers Awards. We are a full-service law firm with a special dedication to tax: Our Tax Practice, one of the most renowned and largest on the Iberian market, with more than 300 lawyers, has been the key legal advisor to many local and global companies. Our leadership is reflected in directories and rankings, where we have been consistently ranked first for many years.

Webpage: http://www.cuatrecasas.com

WTS Global, founded in 2003, is the leading independent tax network. With a current presence in more than 100 countries, we are growing rapidly. Our client base varies from large multinational group to private sector clients. In the Americas, our cooperation between WTS Global, Economics Partners and Lataxnet – a highly rated network of South and Central American law firms, allows us to offer comprehensive tax advisory and transfer pricing services. To avoid potential conflicts of interest, WTS Global members do not offer audit services.

http://www.wts.de/

GSK Stockmann in Luxembourg is a corporate law firm with international reach and additional offices in Berlin, Frankfurt am Main, Hamburg, Heidelberg and Munich. We advise international and domestic clients in the areas of Private Equity, Corporate/M&A, Investment Funds, Capital Markets, Banking/Finance, Real Estate, Insurance and Tax.

We have brought together dynamic, multi-cultural teams of lawyers with a strong capability to analyse complex legal scenarios from different perspectives to find the best solutions to serve the interests of our clients. Our lawyers are registered with the Luxembourg bar and other European or US bars and are active members of working groups organised by bodies of the financial industry in Luxembourg.

GSK Stockmann in Luxembourg thrives to provide the highest quality legal advice and responsiveness combined with a pragmatic approach to meet the challenges and expectations of our clients. Solution driven in our approach, we tailor our services to the exact business needs of our clients.

https://www.gsk.de/en/gsk-luxembourg/

Bronze Sponsors

Badges Sponsors

Thomson Reuters provides professionals with the intelligence, technology and human expertise they need to find trusted answers.

We enable professionals in the financial and risk, legal, tax and accounting, and media markets to make the decisions that matter most, all powered by the world’s most trusted news organization.

Thomson Reuters shares are listed on the Toronto and New York Stock Exchanges

https://www.thomsonreuters.com/en.html

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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.