Global Transfer PricingForum Asia 2013

Why attend? • Learn from the experiences of the leading tax directors at Bharti Airtel, GE, Jabil Circuit, Lear Corporation,

Noble, Nomura, PT Adargo Energy, Schneider Electric, Siemens, Standard Chartered Bank

• Gain updates on the policy issues that will affect your business, including the OECD BEPS project and the UNTP manual

• Get insights into how the tax authorities will approach your tax affairs in the coming years and what you cando to prepare

• Hear case studies about recent transfer pricing disputes in the courts and how you can avoid these costlylitigation issues

• Get an insight into Chinese contract R&D issues

• Learn how to better organise you transfer pricing and indirect tax affairs

• Hear about audit experience in Europe and supply chain management

• Attend industry focused workshops

• Get technical advice on branches versus corporate subsidiaries

Visit: www.internationaltaxreview.com/TPForumAsia2013Call: +44 (0) 20 7779 8334Email: mfabri@euromoneyplc.com

To register:

October 23-24, 2013 • Raffles, Singapore

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08.30 Registration and breakfast

09.00 Chairman’s opening remarks

09.30 BEPS and other policy developmentsWhat the OECD’s Base Erosion and Profit Shifting project will mean for acompany’s tax and transfer pricing arrangements is still unclear, but onething most taxpayers will agree on is that its impact will be significant. Thisdebate will look at:• Recent updates in the project’s development• Economic substance and planning• Permanent establishment issues• What the tax avoidance news headlines really mean

Amit Bhalla, Vice President, Tax & Customs APAC, SchneiderElectricJitendra Jain, Vice President - Transfer Pricing CoE, GEPaolo De Salvia, Group Head of Tax, NobleCheng Chi, Partner-in-Charge, China & Hong Kong, KPMGKari Pahlman, Principal, Asia Pacific Leader, KPMG

10.45 Coffee

11.15 India's APA programmeIndia’s new APA programme is welcome news for any taxpayer withoperations in the country. But, as with many tax developments in India, theprocess is not necessarily straight forward. Taxpayers and experts will taketaxpayers through the specifics of the programme and will provide tips andrecommendations for negotiating with the relevant authorities.• The new programme• How to make the most of your application• How to negotiate with the authorities• Case studies

Kanupriya Prashar, Head of Transfer Pricing, Bharti AirtelNitin Gupta, Director - Tax & Trade, Alcatel LucentS.P. Singh, Transfer Pricing Partner, DeloitteTarun Arora, Transfer Pricing Partner, Deloitte

12.30 Lunch

2.00 Control transfer pricing volatility and drivefinancial performance

Inconsistencies in the implementation of transfer pricing policies pose anumber of challenges for multinational corporations. Learn how the threekey areas of process, people, and technology in operational transfer pricingcan work in tandem for companies to ensure robust execution of transferpricing policies.• Defining processes and controls governing the transfer pricing lifecycle• Maintaining data integrity and consistency• Transforming the standard reactive approach to transfer pricing into an

efficient, intuitive processMichael Velten, Partner, DeloitteVineet Rachh, Head of Tax, Jabil CircuitDavid Jan, Client Service Consultant, Thomson ReutersPrasetyono Hendriarto, Transfer Pricing Specialist, PT AdargoEnergySophie Ashley, Managing Editor, TPWeek.com

3.15 Coffee

3.45 China’s global TP impactChina represents a new global tax and transfer pricing powerhouse with itsown approach to taxation to ensure it gets its fair share of companies’profits. Included in its stance on transfer pricing are the China chapter of theUN’s Practical Manual on Transfer Pricing for Developing Countries.Multinational taxpayers and resident advisers will explain what the UNmanual means for companies and how to negotiate contract R&D matters.• The UN chapter for China: What does it mean?• Contract R&D • Working with authorities on a local and state level• Case studies with valuable lessons

Han Jin Ping, Senior Tax Manager, SiemensCheng Chi, Partner-in-Charge, China & Hong Kong, KPMGKari Pahlman, Principal, Asia Pacific Leader, KPMGFrank Xue, Tax Director – Special Projects, Honeywell International

4.45 Why indirect tax has a significant impact onyou TP department

Transfer pricing is closely linked to customs and other indirect taxes.However valuation, for indirect taxation purposes, can have a significantimpact a company’s transfer pricing strategies and so it is increasinglyimportant to coordinate the two.• Tax effective supply chain management: How to coordinate your indirect

taxes and transfer pricing• Lessons from Europe: Impact of EU VAT DirectiveDouglas Mackay, Indirect Tax & Customs Director Asia Pacific,Lear CorporationDonald Thomson, Partner, Ernst & YoungHenry Syrett, Partner, Transfer Pricing, Ernst & Young

5.45 Chairman's closing remarks

After a successful first year event, welcoming over 150delegates, International Tax Review and TPWeek areholding their second Global Transfer Pricing Forumfor Asia in Singapore on October 23 and 24 at theRaffles Hotel.

The Forum discusses technical transfer pricing issuesand explains how these can affect taxpayers’companies and what tax directors can do to mitigatesthese issues.

Speakers are global and regional heads of tax fromacross the globe, officials from tax administrations

and global organisations and experienced transferpricing advisers, speaking on an international, ratherthan just a regional, level.

This year will focus on the OECD’s BEPS project andwill include practical debates about using branchversus subsidiaries in your corporate structure.

Delegates can also hear discussions about thelegislative developments of permanent establishment,contract R&D in India and China and integratingindirect taxes with transfer pricing, to mention just afew panels.

Global Transfer Pricing Forum AsiaOctober 23-24, 2013 – Raffles, Singapore

Day 1

Visit:www.internationaltaxreview.com/TPForumAsia2013Call: +44 (0) 20 7779 8334Email: mfabri@euromoneyplc.com

To register:

08.30 Registration and breakfast

09.00 Chairman’s opening remarks

09.30 Supply chain restructuringWithout constant attention, it can be easy to let your supply chain becometoo complex and fall into disarray. Companies strive to implement simplifiedmodels but in reality it can be difficult to know where to start. This discussionwill help taxpayers:• Determine best practices• Learn from audit experience in Europe

Vineet Rachh, Head of Tax, Jabil Circuit

Gaetano Pizzitola, Partner, Cross-Border Tax, Crowe Horwath

John Drewno, Transfer Pricing Manager, Caterpillar

10.45 Coffee

11.15 Financial servicesFew industries are more international than financial services. New transferpricing rules and reforms usually have as significant an impact on suchtaxpayers as any others. When you include requirements that are particularto the sector and which also affect transfer pricing, you have a demandingagenda that transfer pricing managers in financial services companies haveto keep on top of. Among the topics this panel will cover are:• What capital and liquidity buffers mean for transfer pricing• Transfer pricing risk management for financial services companies• Latest practice on guarantee fees and its effect on intra-group loan

pricing• Documentation requirements in the financial services industry

Sam Sim, Deputy Head, Global Transfer Pricing, StandardChartered BankJesse Kavanagh, Head of Tax, Asia Ex-Japan, Nomura SecuritiesTobey Hill, Asia Regional Tax Director, CitiPaul Lau, Partner, PwC

12.30 Lunch

2.00 Dynamic developing countries: Indonesia focus

Aside from BRICS nations, dynamic developing countries are undergoingrapid developments in their transfer pricing regimes. Indonesia is a primeexample of these countries and its changes to the legislation over the pastyear will have a big impact on the vast number of taxpayers with dealings inthe jurisdiction.• Regulations update• What this can mean for your business• Implementation issues• What's coming up for Indonesian taxpayers

Herawan Yunendra Hardi, Section Chief of Tax Audit on CorporateGroup Transactions, Indonesian Revenue AuthorityPrasetyono Hendriarto, Transfer Pricing Specialist, PT AdargoEnergySri Wahyuni Sujono, Managing Partner, SF Consulting

3.15 Coffee

3.45 Multinational perspective: A transferpricing controversy presentation by JohnDrewno, Transfer Pricing Manager,Caterpillar

John Drewno manages Caterpillar’s (a multination construction machineryand equipment company) transfer pricing. With a background in the Big4and the IRS, focusing on tax controversy issues, Drewno has also beeninvolved in OECD meeting representing clients in issues relating to theinternational tax aspects of business restructurings project.

In this presentation, Drewno will focus on the Australian SNF case, from amultinational company’s perspective, which prompted a significant overhaulof the country’s transfer pricing regime, and will also discuss live examplesfrom OECD discussions.

4.25 Chairman's closing remarks

Day 2

HotelRaffles Hotel Singapore1 Beach Road, Singapore 189673Tel: +65 6337 1886Fax: +65 6339 7650

Raffles Hotel, established in 1887, has over the years gained internationalrecognition as a traveller’s paradise and is consistently heralded as one ofthe world’s top hotels. Raffles Hotel’s unique charm lies in the harmoniousblend of timeless elegance, classical architecture and extensive tropicalgardens with outstanding contemporary amenities.In l989, Raffles Hotel closed for two and a half years for completerestoration. The restored Raffles Hotel features 103 suites, each tastefullyappointed with period furnishings and modern convenience to cater toevery discerning traveller. The Hotel features 15 distinctive restaurantsand bars and the adjoining Raffles Hotel Arcade houses over 40international and regional speciality stores.

Raffles Hotel, Singapore

Visit: www.internationaltaxreview.com/TPForumAsia2013Call: +44 (0) 20 7779 8334 Email: mfabri@euromoneyplc.com

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