Conference, 3 June 2014, Mandarin Oriental, London, UK
Keynote Speaker: Raffaele Russo, Head of the BEPS project, OECD
Are you aware of all the impacts the OECD’s BEPS project is going to have?
Mismanaging tax risks in an uncertain regulatory environment significantly raises cost burden for international companies across all industries. How can businesses protect themselves from unexpected liabilities? To navigate the increasingly more complex compliance requirements, businesses are relying more on external advisors in creating effective structuring policies. Future-proof your strategies by accessing the most up-to-date information on regulatory developments and the threat they pose to established business practices.
Find out how leading firms identify and monitor intangible asset valuation, transfer pricing and permanent establishment risks from the world’s leading experts, including International Tax Directors of Mars Inc., Reed Elsevier, ASOS.com, Microsoft, Time Warner, Michelin, Omnicom, Kaspersky Lab, Paramount Pictures, As well as a full briefing on the developments of the project and the opportunity to engage directly with Raffaele Russo, Head of the BEPS project, OECD.
SESSION ONE
IP in the Digital Economy: Structuring Implications of Emerging Business Models
Digitalised enterprises tend to pursue innovation as an important element of their competitive advantage and expansion strategies. As a result, high-tech businesses have a greater part of their value driven by intangible property as opposed to physical assets. Efficient R&D and brand-related IP protection and structuring are vital as it affects the future profitability, productivity and sustainability of any company operating in the global marketplace.
Session One examines the challenges of providing a solid basis for accurate IP valuation along with common valuation methodologies and practices
IP structuring experts will discuss the legal aspects of centralisation trends among digital businesses
The panel speakers will debate the issue of the growing enterprise costs in relation to crossborder digital service transactions
SESSION TWO
The Future of Transfer Pricing: Aligning Business and Tax Objectives
Uncertainties surrounding value creation in data-driven supply chains creates an environment where existing transfer pricing regulations need to be revised. However, there is scope for improvement in the transfer pricing processes currently employed. Industry experts will share their experiences of designing and implementing effective policies across different business functions and jurisdictions, in the context of international transparency and cooperative compliance.
Session Two addresses the importance of transfer pricing policy, best practice and risk management awareness among all corporate functions
Plenary speakers will share their experience in planning and implementing effective transfer pricing policy
A multi-disciplinary panel will cover regulatory issues, focusing on transparency and compliance
SESSION THREE
Dealing with the Unintentional Permanent Establishment Exposure Risk
Some aspects of increased business virtualisation challenge and at times directly conflict with the traditional taxation principles. The conference will examine the extent to which the current international law concepts respond to concerns of both business owners and authorities. Attendees and speakers will look into proposed solutions and how the existing business structuring and taxation issues are likely to evolve in the future.
Session Three looks into controversial aspects of the BEPS debate, including the validity of the “virtual permanent establishment” concept
Experienced structuring advisors will clarify the uncertainties of permanent establishment exposure for e-commerce companies operating internationally
Industry professionals will explain the potential implications of proposed country-by-country reporting scheme for non-digital companies
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Since qualifying as a Chartered Accountant in 1967, Roy Saunders has accumulated a wealth of commercial experience working independently in commercial property, international tax, advertising and other industries. He is the Chairman of IFS, a boutique international tax practice based in central London. Academically, he is known throughout the world for his many books and publications, the foremost being his red book, International Tax Systems & Planning Techniques published by Sweet & Maxwell. Roy has also taught an MA Course on International Taxation at the Institute of Advanced Legal Studies at the University of London.
Roy is very proud of the fascinating client base of entrepreneurial individuals that he has built up at IFS. He feels strongly about the role that ethical tax structuring plays in the growth of an economy, and that this needs to be better understood by the public at large. Roy founded the IBSA to enable business professionals around the world to discover new business relationships and promote best practice by creating sustainable business structures compliant with international transparency, corporate governance and social responsibility.
Lorraine works for the BNY Mellon as Managing Director, Head of EMEA Securities Tax and US Tax Services where she provides custody tax technical support to BNY Mellon’s Asset Servicing groups and clients in the EMEA region. She has been heavily involved with a number of trade associations and their work on FATCA, AEOI, EUSD and tax treaty relief initiatives. Lorraine currently chairs the European Banking Federations Tax Reporting and Information Exchange working group. She is an active participant in global initiatives focussing on simplification and harmonisation of tax relief and tax compliance procedures for cross border portfolio investors, as a member of the Business advisory group to the OECD’s TRACE and CRS work and the European Commission’s Tax Barriers Advisory Group T-BAG, both looking at procedures to improve access to tax relief for cross border portfolio investors.
Paul Morton is Head of Group Tax at Reed Elsevier Group plc. He leads a team of 28 tax professionals in London, Amsterdam, Boston and Singapore which serves businesses operating in more than 90 countries. Reed Elsevier is a leading provider of professional information solutions including LexisNexis and the Elsevier Science, Technology and Medical publishing divisions. Prior to joining Reed Elsevier, Paul led the tax team for Royal Dutch Shell’s global marketing and refining division. He held a number of positions before that at Shell including European Internal Audit Manager, Head of Tax for Shell UK and advisor to the exploration and production businesses. Prior to that he was a tax manager at KMPG and he began his career as a tax inspector in the UK Inland Revenue.
Paul is Chairman of the British Branch of the International Fiscal Association and a member of the Confederation of British Industry and FTSE 100 Group Tax Committees as well as the Tax Law Review Committee of the Institute for Fiscal Studies. He is a member of the Council of the Institute for Fiscal Studies, a past member of the Council of the Chartered Institute of Taxation (CIOT) and a past chairman of the CIOT Commerce & Industry Group and the European Branch. He is a past President of the Confederation Fiscale Européenne which represents tax professional bodies in Europe.
Focused, proactive and visionary Executive with extensive financial, business and management experience; recognized for enhancing earnings, identifying value-added opportunities, defining clear objectives and consistently exceeding corporate goals.
Accomplished problem solver, decision-maker and strategist, as well as a public speaker and author, including The Brockman brief, a monthly column in The International Tax Review.
Recognized as a leader within all levels of an organization based upon interpersonal skills, creativity, and proactive nature enhancing individual and team goals and objectives.
Specialties: Proactive Global Tax Executive and Dynamic Leader with extensive hands-on experience in M&A, global tax planning, US and foreign tax audits, transfer pricing and international tax structuring.
Introduce "Best Practices" and coordinate in-house tax presentations for US GAAP FAS 109 (ASC 740), including FIN 48. Collaboratively develop tax-efficient funding and repatriation strategies.
In 1998 Jose Villoldo qualified as a lawyer specialising in International Corporation Taxation with the law firm Linklaters (in Paris & Luxembourg). He was admitted to the Parisian Bar in 1998 and to the Luxembourg Bar in 2000 and become a member of the Law Society of England and Wales in 2002.
Jose joined Omnicom Europe in London in September 2002 as the EMEA Senior Tax Manager to look after Omnicom’s EMEA tax affairs – these include, amongst other things, providing tax advice and tax planning in areas such as corporate restructurings, M&A, transfer pricing, VAT, managing the group’s global effective tax rate and tax audits. Jose has headed the EMEA Tax Department since 2006.
Harm J. Oortwijn is Director of International Tax with Paramount Pictures (a Viacom company). He has 20 years of international tax experience with a number of multinational companies as both in-house professional and tax consultant. He is well-versed in international tax software & solutions development, US & international tax planning and compliance, US GAAP & IFRS tax accounting principles and ERP tax implementation issues. He studied chartered public accountancy at Hogeschool Windesheim in Zwolle, Netherlands and graduated with honors from United Business Institutes in Brussels with a master’s degree in global tax management.
Gary Howlett has a 20 year career as a tax executive in both consulting and in-house corporate positions and specializes in implementing tax efficient supply chain structures. Effective September 2010 Gary was appointed Global Tax Director at Kaspersky Lab, the largest private internet security software company. Prior to that, Gary was International VP of Tax at Yahoo, based in Switzerland and responsible for tax strategy outside the Americas. He spent a significant part of his career as Global Tax Director at Silicon Graphics and previously in his career Gary worked in tax consulting, starting at PWC and eventually forming his own consulting practice.
Andrew Hewitt was appointed Head of Tax at ASOS PLC in October 2012 where he has been responsible for building a tax structure to support a rapidly expanding global business. Prior to that he was Head of EMEA Tax at Sabre Holdings, responsible for EMEA transfer pricing, planning, compliance and risk management. He worked at Sabre for 5 years and was involved in the resolution of a number of transfer pricing disputes. Before that, Andrew spent 7 years at Ernst & Young and has also been involved in the Digital Economy Stakeholder Group run by HM Treasury.
A member of the Senior Management Team of the OECD Centre for Tax Policy and Administration (Paris), Raffaele Russo currently coordinates the work on Base Erosion and Profit Shifting (BEPS), an ambitious project aimed at redesigning the rules for the taxation of cross-border profits.
Previously, Raffaele was Head of the Non-Compliance Unit at the OECD Centre for Tax Policy and Administration, in charge of the work on Aggressive Tax Planning and on Tax Crimes. Prior to that, he worked on the OECD Model Tax Convention and the OECD Transfer Pricing Guidelines, as well as on Exchange of Information matters when he drafted the Protocol to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
Raffaele regularly leads OECD missions in non-member countries and at the OECD Multilateral Centers.
Before joining the OECD, he was a Senior Associate at the International Tax Academy of the IBFD (Amsterdam) and a Tax Lawyer with NCTM Studio Legale Associato (Milan). He obtained his Law Degree from the University Federico II (Naples, Italy), and his LLM in International Taxation from the University of Leiden in the Netherlands, both cum laude.
He is the author of several articles on international tax matters and editor and co-author of the books ‘The Attribution of Profits to Permanent Establishments: The taxation of intra-company dealings’ (2005), ‘Fundamentals of International Tax Planning’ (2007) and ‘A Decade of Case Law: Essays in honor of the 10th Anniversary of the Leiden LLM in International Taxation’ (2008). Raffaele has published articles in Italian, French, English, Spanish, Polish, Russian and Portuguese. He is a frequent speaker at conferences and seminars.
Francois Thomas is a senior tax professional with over 20 years as tax Counsel and tax lawyer. He spent 8 years as Senior Tax Counsel with Michelin, working in France and also serving as a Regional Tax Counsel for Asia-Pacific for 2 years. In this role Francois was responsible for dealing with tax and customs issues in China, Hong Kong, India, Indonesia, Japan, Korea, Malaysia, Philippines, Singapore, Thailand, Taiwan and Vietnam. He is an expert in industrial investments, cash pooling, supply chain, acquisitions & restructuring, R&D, headquarter expenses, monitoring Permanent Establishment exposure. Francois also has a strong professional focus on intra-group transactions: transfer pricing policy implementation, adaptation, enforcement and defence, including negotiation of advanced pricing agreements with tax authorities. Previously he spent 9 years practicing at PwC and E&Y.
Andrew Caldwell has 30 years of experience in the valuation of private companies, intellectual property, unincorporated businesses, and associated assets and liabilities. These have been for commercial, fiscal, statutory, financial reporting, and “fair value” purposes, both within the United Kingdom and internationally, including acting for FTSE 100 clients. Andrew has been involved in litigation support for both national and international jurisdictions. In 2008, Andrew was appointed by HM Treasury as the Independent Valuer for the Northern Rock Compensation Scheme. He is a founding member of the Expert Witness Institute, a founding council member of the Society of Share and Business Valuers, and a Fellow of the Royal Institution of Chartered Surveyors. Before joining BRG, he was the senior valuations partner with BDO LLP.
Professor Ghafele is the Managing Director of Oxfirst Limited, a consulting firm specialising in the economics of IP. She holds permanent faculty positions in law and business school with the Universities of Oxford and Edinburgh, has published with Harvard and Oxford University Press and held a Research Fellowship with the Haas School of Business, University of California at Berkeley. Previously she worked as an economist with the World Intellectual Property Organization (WIPO) and the Organization for Economic Cooperation and Development (OECD), offering strategic advice on Intellectual Property, Trade and Innovation to Governments in Europe, Asia and the Middle East. She started her career with the management consulting firm McKinsey & Company. Her Ph.D. was awarded the Theodor Koerner Research Prize by the President of the Republic of Austria.
Matt Rainey is Director of the Innovation Division at the WIPO, responsible for issues relating to innovation policy and infrastructure, SMEs (small and medium-sized enterprises) and other IP rights holders, universities and technology transfer issues and processes.
Mr. Rainey joined WIPO after nearly thirty years of IP law practice in both large and small companies and law firms, in the United States and for some time in Munich. His legal work has involved patent, trade secret, copyright and trademark protection, strategies, commercialization and litigation. He has focused on patent law, and before joining WIPO he specialized in IP and innovation policy, including extensive work on legislative, judicial and administrative matters relating to IP law, processes and policy.
Mr. Rainey holds a degree in Physics from the University of Maryland and a law degree (J.D.) from the University of Southern California School of Law.
Omleen was formerly Director of International Tax in the Tax Strategy & Benefits group at Squire Patton Boggs, a global law firm.
She has extensive experience, from over 14 years of practice, in prominent City firms, of a very wide range of cross-border corporate, real estate, funds and financing tax issues and structures. She has worked with FTSE 100 companies, Fortune 100 companies and major international banks, funds and financial institutions. She has vast experience advising financial institutions on international tax structuring, compliance and risk management, in the context of recent intergovernmental, EU and OECD initiatives on international tax transparency and exchange of information.
Over a number of years, she has advised members of the UK House of Lords and several UK Government departments on various matters relating to international business. She is regularly invited to travel abroad with high-profile UK Government business delegations. She has also been involved in consultations on a number of EU-wide and OECD-level international initiatives. She is regularly invited to speak at high-profile conferences and events. She has also written for journals and books, on issues relating to corporate tax, international tax and international business relations.
Having trained and worked as a corporate tax manager in the Big 4, Helen Blenkinsop has worked as a Tax Director in-house for 20 years, mostly within small head office teams where all individuals have a high degree of responsibility. “It is important to be flexible and cover VAT and employment taxes as well as corporation tax – and above all, focus on earnings and practicality,” Helen says. She was Tax Director of Albright & Wilson PLC when it floated into the FTSE250, and set up the tax function at Imperial Tobacco Group PLC. Since then, Helen has carried out interim assignments within a variety of sectors such as retail, media and FS, and is currently on assignment within the service sector.
IFS is a boutique international tax practice specifically created to assist entrepreneurial clients with innovative long term commercial structures for their businesses. IFS routinely provides advice in Corporate Transactions, Transfer Pricing, Mergers and Acquisitions, Structured Finance Deals, Royalty and IPR Transactions, Private Equity and Venture Capital Funds, International Real Estate, Changes of Personal Residence, Corporate Redomiciliation, Internationally Mobile Individuals, Taxation of Entertainers and Sportsmen and Global Employment Solutions.
Offering views over Knightsbridge and the royal park, Mandarin Oriental Hyde Park is one of London’s most distinguished hotels.
HOTEL INFORMATION
ADDRESS
66 Knightsbridge
London SW1X 7LA
United Kingdom
PHONE
+44 (0) 20 7235 2000
+44 (0) 20 7201 3773
TRANSPORT
The nearest tube station is Knightsbridge on the Picadilly line. The hotel is a 2 minute walk from the station, located on the south east corner of Hyde Park.
International Business Structuring in the Digital Economy is an event you don’t want to miss! You’ll hear from thought leaders on international business strategy, explore the current and future policy landscape, and exchange ideas and experiences as you network with your peers.
Who will attend?
- Corporate Tax Directors
- Corporate Finance Directors
- Corporate Heads of Transfer Pricing
- Corporate Head of IP
- Corporate Heads of Strategy
- Solicitors
- Barristers
- Partners
- Wealth Managers
- Tax Advisers
- IP Consultants
- Business Consultants
- In-house Counsel
Who attended in 2013?
13 Old Square Chambers, Aston Bond, Averose Chancery Chambers, Baker and McKenzie, Barclays, BDO, Bilanz Data, Blokh Solicitors, British Renewables, C Partners, Capita, Coller IP, Dafisa EuroTrust International Consulting Ltd, Dechert, DEFAP Group, DKLM, Equinor, Farrer & Co, Focusrite, Four Seasons Ventures, Frank Hirth, Genworth, Gray's Inn Tax Chambers, Herbert Smith, Hermitage Private Office, Hil Law Belgium, IFS, IML Group, Intrust, Invest Barbados, InvestHK, JAG Capital, John Cumming and Partners, K&L Gates, Kaiser Partner, Kelmer & Partner, King and Spalding, Kryso Resources, L'Alliance Révision S.à r.l, Lenz & Staehelin, McCarthy Fingar LLP, Memery Crystal, MGAP, MHA MacIntyre Hudson, Middleton Katz, Nigel Sloam Associates, Opus Group, Orangefield Group, Padva, Haslam-Jones & Partners, Pinsent Masons, PJR Limited, Praxis Lux. SA, Proximitas Steuerberatungsges, PWC Lisbon, R&P Consulting, Rooks Rider, Royal Bank of Canada, S. Droussiotis Real Estates Ltd, SARL C.E.E.C, SDM, Shine Law, Shipleys, Shladot Ltd., Smith & Williamson, Stikeman Elliott LLP, The ILS Group, Totalserv Mangement, Vincena, Vohkus Ltd.
Testimonials: What did the the delegates say?
"Presentations were very clear and to the point, very topical and significant."
Jay Sanghrajka, Shipleys LLP
"Presentations on creating futures were most useful. The narratives of disruption and the opportunity they presents appeal to our investors."
Nigel Pardoe, Hermitage PO
"Presentations that linked IPR rights and valuation, and those bridging the gap between estate planning with corporate tax planning for global business families were most useful."
Carl Islam, Averose Chancery Chambers