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Executive Education
Clariden Leadership Institute
Tax Efficient Transfer Pricing and Intra-Group Financing (UK)
Carine Stoffels
International Tax Expert

This program has been independently accredited and certified by CPD
Carine Stoffels, International Tax Expert

 

  • Expert consultant for IMF, London School of Economics, and other private clients on tax law, policy and compliance issues
  • Former tax advisor for OECD, advising OECD member countries, G20 non-member countries and other non-member countries on tax law, policy and compliance matters, including the implications of the OECD/G20’s Base Erosion and Profit Shifting (BEPS) Project
  • UK and Belgian qualified tax lawyer with 17 years of international tax experience both in private practice and in the international tax policy arena
  • Speaker and training facilitator at various international tax conferences and seminars

 

Carine Stoffels is a trusted international tax expert, advising IMF, London School of Economics Enterprise, and other private clients on tax law, policy and compliance issues. She started off her career as a tax lawyer for almost nine years, working, first, in Belgium, then in the UK before moving on to her former role in OECD.

 

Prior to becoming an independent tax consultant, Carine has been Advisor within the International Co-operation and Tax Administration Division of the OECD’s Centre for Tax Policy and Administration, where she was heavily involved in the OECD's work on aggressive tax planning and exchange of information. Carine led a series of regional and country-specific OECD workshops, seminars and other training and capacity building events for tax administrations in OECD and non-OECD member countries.

 

With 17 years of consulting experience with respectable financial institution such as OECD and IMF in the field of tax management, Carine has garnered years of expertise in aggressive tax planning and tax compliance. She has been a frequent speaker and facilitator at various workshops, seminars, and conferences around the world.

 

Carine completed the International Tax Program at Harvard Law School, Advanced Specialised Studies in International and European Law and an Advanced Degree in Tax Law at the University of Brussels. She was admitted to the roll of solicitors in England and Wales in October 2009 and was a member of the Brussels Bar as a Belgian qualified lawyer from October 2000 to June 2010.

Other Faculty Speakers

Giammarco Cottani
Ludovici Piccone & Partners
Head of Transfer Pricing
  • Transfer pricing expert, providing technical assistance to developing countries on behalf of the UN and World Bank 
  • Member of the UN Sub-Committee Group in charge of the Draft of the Practical Manual on Transfer Pricing for Developing Countries
  • Former transfer pricing advisor for OECD. Participated in the work of WO6 regarding the revision of Chapter I-III of the OECD TP Guidelines and the inclusion of the new Chapter IX on the transfer pricing aspects of business restructurings
  • Author of various articles in transfer pricing journals and publications

 

Giammarco Cottani is partner and head of transfer pricing practice at Ludovici Piccone & Partners, a leading Italian tax law firm. He currently serves as a Member of the Sub-Committee Group of the United Nations in charge of the Draft of the Practical Manual on Transfer Pricing for Developing Countries, and he is also the Delegate for Italy on a number of OECD Working Parties.

 

Until August 2015, Giammarco acted as Advisor on International Tax to the Central Assessment Director of Italy Revenue Agency. He was one of the delegates for Italy involved in the OECD BEPS project. Prior to joining the Agency, he worked as a Transfer Pricing Advisor in the Tax Treaty and Transfer Pricing Unit of the OECD, where he was involved in the introduction of the new Chapter IX of the OECD Transfer Pricing Guidelines concerning business restructurings.

 

With experience around the globe with reputable organisations, Giammarco possesses deep understanding in the field of transfer pricing. He is a member of the faculty of the International Tax Center, the University of Leiden for transfer pricing. He regularly lectures in postgraduate courses in international tax, with a specific focus on transfer pricing, both in Europe and the United States. Giammarco is currently providing technical assistance for a number of tax administration projects in several LATAM countries on behalf of World Bank and the UN.

This course has been independently certified as conforming to accepted CPD guidelines. On average, this executive program contributes 16 hours towards your CPD.

Program Summary

 

Since Apple's unprecedented $14 billion tax penalty by the European Commission in August, tax authorities worldwide, especially in Europe, are now scrutinising international companies' tax practices to examine their structures and compliance. In fact, EU Commissioner has warned that this is only the beginning for international firms. To help you achieve full tax compliance and efficiency in your tax planning, Clariden is pleased to invite you to our two-day Tax Efficient Transfer Pricing and Intra-Group Financing programme this May.

 

Led by a former advising international tax expert for OECD and IMF—Carine Stoffels, and her partner, tax advisor to World bank, OECD, and UN—Giammarco Cottani, this comprehensive programme will show you as tax leaders how to develop your intra-group financing and transfer pricing strategy to ensure your organisation's tax structure is efficient and at the same time, tax compliant with financial and tax legislations, and in local statutory requirements, which are dynamic in nature. Carine and Giammarco will walk you through the latest developments and issues of transfer pricing, as well as authorities’ perspective on the matters. You will have the chance to explore how to carry out transfer pricing analysis with different business models to improve your business efficiency.

 

In addition, Carine and Giammarco will shed light on measures of value chain optimisation, in order to maximise tax benefits with a cost-effective value chain framework. You will also gain insights on the latest developments of BEPS and explore considerations such as hybrid mismatch arrangement, controlled foreign company, interest deductibility, and many more, to help you ensure tax compliance and minimise / avoid tax disputes.

 

Through case studies and interactive discussion, Carine and Giammarco will challenge you intellectually and stretch your thoughts constructively throughout the programme. She will guide you to make sense of current transfer pricing principles and better control transfer pricing practice, so you can guard your profit against unnecessary loss.



Programs, dates and locations are subject to change. In accordance with Clariden Global policy, we do not discriminate against any person on the basis of race, color, sex, religion, age, national or disability in admission to our programs.

Introduction

 

With transfer pricing row hanging over corporate giants like Apple and Facebook in 2016, transfer pricing continues to be a main priority for multi-national corporations. As penalties for found cases of transfer pricing have extended not only to financial terms, but also in terms of reputation damage and extra scrutiny from tax authorities, businesses are taking extra measures to help themselves navigate through the complex sea of international tax legislations and guidelines.

 

Understand your need for better transfer pricing insights, this comprehensive two-day programme will help tax professionals improve your intra-group financing practices and protect your organisations’ bottom line. Led by an international tax expert for OECD and IMF, Carine Stoffels, and her partner, tax advisor to World bank, OECD, and UN – Giammarco Cottani, this programme will show you how to develop intra-group financing strategies to achieve tax-effectiveness with different business models.

 

This comprehensive programme will shed light on issues surrounding transfer pricing and tax regulation developments around them. Carine and Giammarco will show you how to align your intra-group financing plan with your organisation’s supply chain framework. Our facilitators will walk you through the steps of value chain optimisation to achieve tax-effectiveness. You will also have the chance to look at transfer pricing from tax authorities’ perspective and learn how different financing aspects, such as hybrid mismatch arrangements, controlled foreign company, and interest deductibility, affect your intra-group financing strategy.

 

Through case studies and interactive discussion, Carine and Giammarco will challenge intellectually and stretch your thoughts constructively throughout the programme. By the end of the course, you will be able to make sense of current transfer pricing guidelines, better control transfer pricing practice, and guard your profit against unnecessary loss.

 

 

What You Can Expect

 

  • Stay on top of current transfer pricing and intra-group financing developments in the region
  • Discover the application of transfer pricing to common business models 
  • Explore measures to achieve tax-effectiveness with value chain optimisation
  • Understand different types of intra-group financing activities
  • Discover transfer pricing considerations, such as hybrid mismatch arrangements, controlled foreign company, interest deductibility, to build better transfer pricing strategies
  • Learn to apply BEPS guidelines to financing models and ensure tax compliance

Who Will Benefit Most

 

This program is designed for but not limited to tax specialists, finance and accounting professionals, trade and customs professionals, supply chain and logistics experts who are seeking to learn or increase their experience with international tax, indirect tax and transfer pricing concepts, as well as MD / GM / CEO and Head of businesses who are considering restructuring their businesses.

Program Outline

 

DAY 1 – TRANSFER PRICING

 

Session 1: Setting the scene

  • Transfer pricing in general and transfer pricing of intra-group financing specifically: an area of growing scrutiny and controversy
  • Tax authorities’ focus on transfer pricing further advanced by the OECD’s BEPS Project and other developments, including through country-by-country reporting
  • Impact of those developments on business (re)structuring, compliance and risk management strategies

 

Session 2: Transfer pricing and supply chain management

  • Common business models – Key concepts: Business restructurings of manufacturing and distribution functions – Intellectual property management
  • The application of transfer pricing methods to post-restructuring scenarios – The notion of control over risk and financial capacity to assume the risk

 

Session 3: The management of supply chain in the new BEPS landscape

  • Value chain analysis: concept; tax-effectiveness and the role of CCAs
  • Value Chain and Intercompany services
  • The new transfer pricing landscape post-BEPS (BEPS Actions 8-10; 13)
  • Value chain optimisation and proper transfer pricing documentation

 

DAY 2 – INTRA-GROUP FINANCING: TRANSFER PRICING AND NON-TRANSFER PRICING ASPECTS

 

Session 4: Importance and types of intra-group financing

 

Session 5: Impact of BEPS and other developments on intra-group financing

  • Transfer pricing aspects of intra-group financing (BEPS Actions 8-10; 13)
  • Non-transfer pricing related aspects of intra-group financing: hybrid mismatch arrangements (BEPS Action 2), controlled foreign company (CFC) rules (BEPS Action 3), interest deductibility (BEPS Action 4), harmful tax practices work (BEPS Action 5), Preventing tax treaty abuse (BEPS Action 6)

 

Sessions 6 - 7: Case study and conclusions regarding sustainable transfer pricing policies and finance models

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Venue: Conrad London St James
Date: 22 - 23 May 2017
Faculty: Carine Stoffels
Early Bird 1: £1,795 (by 27 Mar 2017)
Early Bird 2: £1,895 (by 24 Apr 2017)
Regular Fee: £1,995
Group Discount: 2nd participant get 10%, or register 3 participants and 4th participant get a complimentary seat
(1 discount scheme applies)
Contact: karen.woods@claridenglobal.org
 
 
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