2022 WU Transfer Pricing Symposium: Transfer Pricing and Business Restucturings
By presenting and analysing detailed case studies, the 2022 WU Transfer Pricing Symposium aims bringing togetherrelevant international players in the transfer pricing area (coming from academia, international organizations, governments as well as the business and advisory communities), in order to discuss the relevant issues and to find common solutions to the current problems.
Content and structure
Thursday, October 20, 2022
18.30-21.00 Welcome Reception
Friday, October 21, 2022
09.00 – 09.15 Welcome Address
09.15 – 10.45 Session 1: Delineating and Recognizing Business Restructuring
In the last few years, the focus on issues related to transfer pricing and business restructuring has been significantly increasing. Circa 15% of the total transfer pricing case laws in 2020-21 have disputed these issues. What constitutes a business restructuring under transfer pricing rules is a colossal primary step. Whether there is a termination or a substantial renegotiation of existing arrangements or the transfer of something of value thereby modifying the profit (or loss) potential are important determinative factors. This session will examine, by analyzing practical case studies, some of the essential characteristics of business restructuring related with the issues of identifying the commercial or financial relations that lead to the proper delineation and recognition of this type of transactions within multinationals.
11.15 – 12.45 Session 2: Remunerating the Restructuring Itself
Remunerating the restructuring is a complex exercise, which takes into account, inter alia, elements such as cost of restructuring, use of tangible and intangible assets, ongoing concerns, valuation techniques. Based on practical case studies, this session will discuss the different approaches in determining the arm’s length remuneration of the restructuring itself.
14.00 – 15.30 Session 3: Remunerating the Post-Restructuring
Remunerating the post-restructuring transaction is an equally important exercise in the whole business restructuring process. This process entails identifying which entities undertake functions, assets and risks in a post-restructuring scenario. In this regard, this session will highlight post-restructuring issues through practical case studies and ascertain the arm’s length value of such transactions.
16.00 – 17.30 Session 4: Other Relevant Issues
Changes in functional and risk profiles and transfer of something of value in business restructuring could engender issues pertaining to, inter alia, location-specific advantages, group synergies, compliance, intersections with local domestic anti-avoidance rules (e.g. exit taxes), as well as VAT and customs. This session, based on case studies, aims to focus on some of these topics.
17.30 – 17.40 Concluding remarks
Speakers
RAFFAELE PETRUZZI (Italy/Austria)
Managing Director, WU Transfer Pricing Center, WU
Of Counsel, Baker McKenziePAOLO VALERIO BARBANTINI (Italy)
Deputy Director General, Italian Revenue AgencySVITLANA BURIAK (Ukraine/The Netherlands)
Transfer Pricing Specialist, Loyens & Loeff
Assistant Professor, University of AmsterdamGIAMMARCO COTTANI (Italy/The Netherlands)
Director, Global Tax Policy, NetflixROMAN DAWID (Germany)
Partner, PwCMANUEL DE LOS SANTOS (Spain/France)
Head of the Transfer Pricing Unit, Centre for Tax Policy and Administration, OECDGIANNI DE ROBERTIS (Italy)
Partner, KPMG ItalyYING GU (The Netherlands)
Director, Transfer Pricing & Global Enterprise Model, SABICEMILY MUYAA (Kenya/United States)*
Chief, Capacity Development Unit, UNDESA, United NationsKATARINA PETOVSKA (Slovakia)
Global Transfer Pricing Operations and Economics Lead, Dell TechnologiesSAYEE PRASANNA (India/Germany)
Manager, International Tax and Transfer Pricing, Ernst & YoungNATALIE REYPENS (Belgium)
Partner, Loyens & LoeffMARIA TERESA RUIZ DE AZUA (Spain)
Transfer Pricing Group Director, Procter & GambleDOMINIC VINES (United Kingdom)
Team Leader, Transfer Pricing (APA & MAP) Team, HMRC
* pending final confirmation
Brochure
Registration & practical information
Registration Form
To register, please fill out and submit your registration form to
transferpricingcenter@wu.ac.at.
Participation fee
The participation fee for the event is EUR 650.-
A 20% “early bird discount” is applicable to registrations received by August 29, 2022.
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.
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 8, 2022, 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.