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2023 WU Transfer Pricing Symposium: Transfer Pricing Aspects of the Recent EU State Aid Cases
The WU 2023 Transfer Pricing Symposium will analyse and debate four state aid cases –Amazon, Apple, Starbucks and Fiat – from a transfer pricing perspective. Representatives from academia, advisory, business, government and international organisations will provide their views and insights on those cases. The symposium will not delve into the arguments on the existence of state aid.
Content and structure
The initiation of state aid cases involving tax rulings granted to some large multinational enterprises created quite a buzz in tax circles. Long standing transfer pricing arrangements were unraveled as companies were confronted with significant new potential tax liabilities, coupled with interest. As the gavel comes down on the existence of state aid, the 2023 WU Transfer Pricing Symposium turns the lens to the transfer pricing aspects of those cases.
The sessions will analyse the transfer pricing issues of selected state aid cases – Amazon, Apple, Starbucks and FIAT – using the facts made public in the various discussions. As for any transfer pricing analysis, the debate will start with the application of the four-steps transfer pricing analysis to each case, that is, accurate delineation of the transactions, recognition of the accurately delineated transactions, selection of the appropriate transfer pricing method, and application of the selected method. Following this, the dialogue will delve into other relevant transfer pricing issues arising from the selected cases.
Representatives from academia, advisory, business, government and international organisations will provide their views and insights on those cases. The symposium will be limited to transfer pricing issues and will not veer into the state aid analysis of the cases, that is, whether there was a selective advantage in accordance with the state aid rules of the European Union.
Thursday, October 19, 2023
18.30-21.00 Welcome Reception
Friday, October 20, 2023
09.00 – 09.15 Welcome Address
09.15 – 10.45 Session 1: the Amazon case
11.15 – 12.45 Session 2: the Apple case
14.00 – 15.30 Session 3: the Starbucks case
16.00 – 17.30 Session 4: the FIAT case
17.30 – 17.40 Concluding Remarks
Speakers
RAFFAELE PETRUZZI (Italy/Austria)
Managing Director & Chair, WU Transfer Pricing Center, WUDANNY BEETON (United Kingdom)
Director, Beeton Consulting LimitedRÓBERT CSABAI (Hungary)
Head of International Taxation and Transfer Pricing Department, Ministry of FinanceGREGOR GEHAUF (Germany)
Team Lead Tax BMW Bank, BMW GroupJEAN-LOUIS GEYR (Switzerland)*
former Senior Vice President & Group Head of Global Tax, Finance & Control, NestléTREVOR GLAVEY (Ireland)
Solicitor and Chartered Tax Advisor, MathesonSIMON HOFSTAETTER (Austria)
Expert International Taxation, Tax Authority for Large Business, Federal Ministry of FinanceASTRID JOGERUD (Norway)
Senior Legal Adviser, The Norwegian Tax AdministrationSEEMA KEJRIWAL JARIWALA (India)
Partner, BMR Legal AdvocatesMARTIN LAGARDEN (Germany)
Head of Global Transfer Pricing, Henkel AG & Co. KGaARUTH MIREMBE (Uganda/Austria)
Research and Teaching Associate, Institute for Austrian and International Tax Law, WUOMAR MOERER (The Netherlands)
Partner - Financial Services Transfer Pricing, DeloitteJÉRÔME MONSENEGO (France/Sweden)
Professor of International Tax Law, Stockholm UniversityMARCELO H.B. MOURA (Brazil/Austria)
Research and Teaching Associate, Institute for Austrian and International Tax Law, WUFEDERICO PACELLI (Italy)
Partner, International Tax and Transfer Pricing, DLA PiperABHISHEK PADWALKAR (India/Austria)
Research and Teaching Associate, Institute for Austrian and International Tax Law, WUKATARINA PETOVSKA (Slovakia/Austria)
Global Transfer Pricing Operations and Economics Lead, Dell TechnologiesALAIN STEICHEN (Luxembourg)
Partner, BSP
Associated Professor, University of LuxembourgÁGATA UCEDA (Spain/The Netherlands)
Partner, KPMG Meijburg & CoISABEL VERLINDEN (Belgium)
Partner Corporate Tax Strategy - Transfer Pricing, PwC
University Lecturer
* pending final confirmation
Registration & practical information
Participation fee
The participation fee for this event is EUR 650.-
A 10% “early bird discount” is applicable to applications received by August 29, 2023.
A waiver on the registration fee can be granted to applications from researchers exclusively employed by an academic institution. To apply, please submit a short letter of motivation including the relevance for your research, together with your CV and a list of recent publications to transferpricingcenter@wu.ac.at.
The participation fee covers all materials, lunch, coffee breaks and refreshments. Costs of travel and accommodation are not included.
Payment
You will receive an invoice for the participation fee of EUR 650.- (or of EUR 520.- in case of the “early bird discount”). We kindly ask you to transfer your payment within three weeks from the date of the invoice.
Cancellation
Any notification of cancellation of registration must be sent in writing to: transferpricingcenter@wu.ac.at. In case of cancellation before October 5, 2023, the participation fee will be refunded. No refund can be made for cancellations received after this date.
Photos
We would like to inform you that this event will be photographed. Should you not wish for your image to be taken, we kindly ask you to avoid the camera and/or inform Ms. Christina Sudrat (christina.sudrat@wu.ac.at). Photos will be used to inform the public about the activities of the Institute for Austrian and International Tax Law.
