Global Transfer Pricing CourseAdvanced Topics

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ContentCourse Overview 2

Target Group 3

Period 3

General Information 3

Content and Structure 4

Lecturers 6

Lunches, Coffee Breaks, and Dinner 10

Course Materials 10

Course Level and Prerequisites 10

Venue 10

Course Fees 11

Questions and Contact 11

Registration 12

Application Form 13

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Course OverviewThe increasing global trade and the role of multinational enterprises in the global economy have boosted the relevance of transfer pricing topics. The number of countries having transfer pricing legislation in place has increased from a mere four in 1994 to more than 80 in 2014. Therefore, transfer pricing is one of the most relevant and challenging topics in the international tax environment.

The Global Transfer Pricing Course (Advanced Topics) offered by the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business (WU, Vienna (Austria)) (www.wu.ac.at/en) meets the increasing demands for education in this field by offering high quality training. With renowned experts from all over the world as lecturers, training at the highest international level with a great degree of practical relevance is guaranteed.

The Institute for Austrian and International Tax Law (www.wu.ac.at/taxlaw/en) is one of the global leading tax academic institutions and is extremely active in the field of international taxation. As well as research and teaching activities, its staff participate in numerous national and international tax projects and over the years has developed an impressive network of contacts in more than 90 countries. The Institute’s team comprises of 60 academic staff members as well as many visiting professors and guest researchers from around the world.

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Target GroupThe course is targeted at professionals around the world who want to broaden their knowledge of transfer pricing. Participants are typically tax and transfer pricing advisors (accountants, economists, and lawyers), in-house tax and finance employees of international companies, government officials, and academics.

PeriodThis 5-day course will be held on September 21-25, 2015.

The course is entirely held in English.

In order to guarantee a high degree of interactivity, the course is limited to a maximum of 30 participants. Early registration is therefore recommended.

The course is structured into three sessions per day of 1,5 or 2 hours each. Each day is completed by a session of 30 minutes of conclusive remarks. Each topic is analyzed with a mix of theory and workshops (with case studies).

General InformationW

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Monday, September 21, 2015Transfer Pricing and Services09.00-10.30 Transfer Pricing and Services: Setting the Scene Danny Houben

11.00-12.30 Managerial and Administrative Services; Shareholder Activities; Low Value-Adding Services Oliver Wehnert

12.30-13.00 Workshop Oliver Wehnert

14.30-16.00 High Value-Adding Services; E-Commerce Mukesh Butani

16.30-17.00 Workshop Mukesh Butani

17.00-17.30 Conclusive Remarks on Transfer Pricing and Services Alfred Storck and Raffaele Petruzzi

Tuesday, September 22, 2015Transfer Pricing and Financing09.00-10.30 Transfer Pricing and Financing: Setting the Scene Stephanie Pfeifer

11.00-12.30 Loans and Cash Pooling Michael van der Breggen

12.30-13.00 Workshop Michael van der Breggen

14.30-16.00 Financial Guarantees, Factoring, Foreign Exchange and Derivatives, Other Forms of Financing and Credit Risk Arrangements Antonio Russo

16.30-17.00 Workshop Antonio Russo

17.00-17.30 Conclusive Remarks on Transfer Pricing and Financing Alfred Storck and Raffaele Petruzzi

Wednesday, September 23, 2015Transfer Pricing and Intangibles09.00-10.30 Transfer Pricing and Intangibles: Setting the Scene Robert Risse

11.00-12.30 Characterizing Transactions; Licence Model; Cost Contribution Arrangements/Cost Sharing Agreements Isabel Verlinden

12.30-13.00 Workshop Isabel Verlinden

Content and Structure

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14.30-16.00 Migration and Valuation of Intangibles; IP Boxes Emmanuel Llinares

16.30-17.00 Workshop Emmanuel Llinares

17.00-17.30 Conclusive Remarks on Transfer Pricing and Intangibles Alfred Storck and Raffaele Petruzzi

Thursday, September 24, 2015Transfer Pricing, Supply Chain Management and Business Restructurings09.00-10.30 Transfer Pricing, Supply Chain Management and Business Restructurings: Setting the Scene Graeme Wood

11.00-12.30 Tax-Effective Supply Chain Transformation; OECD/UN Transfer Pricing Guidelines on Business Restructuring; Restructuring of Intangibles Caroline Silberztein

12.30-13.00 Workshop Caroline Silberztein

14.30-16.00 Business Restructuring and Permanent Establishments Andreas Oestreicher

16.30-17.00 Workshop Andreas Oestreicher

17.00-17.30 Conclusive Remarks on Transfer Pricing, Supply Chain Management and Business Restructurings Alfred Storck and Raffaele Petruzzi

Friday, September 25, 2015Transfer Pricing, Indirect Taxes and Customs09.00-10.00 Transfer Pricing and Customs: Setting the Scene Ian Cremer

10.00-10.30 Transfer Pricing and Customs: Discussion and Q&A Ian Cremer, Peter Eisenring, Barbara Schmid and Ruud Tusveld

11.00-13.00 Transfer Pricing and Customs: Principles, Comparison, and Conflicts; Workshop Peter Eisenring and Barbara Schmid

14.00-16.00 Dealing with VAT and Customs Valuation in a Transfer Pricing Environment (Including Complex Value Chains and Modern Business Structures); Workshop Ruud Tusveld

16.00-16.30 Conclusive Remarks on Transfer Pricing, Indirect Taxes and Customs Alfred Storck and Raffaele Petruzzi

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LecturersLecturers are international leading transfer pricing experts from academia, international organizations, the business community, and advisory firms.

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Prof. Dr. Alfred Storck (Switzerland/Austria)

Professor of Transfer Pricing and International TaxationInstitute for Austrian and International Tax LawVienna University of Economics and Business (WU)Vienna (Austria)

Dr. Raffaele Petruzzi, LL.M. (Italy/Austria)

Research Associate in International Taxation and Transfer PricingInstitute for Austrian and International Tax LawVienna University of Economics and Business (WU)Vienna (Austria)

Transfer Pricing AdvisorDeloitteVienna (Austria)

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Mukesh Butani (India)

Transfer Pricing Leader Managing PartnerBMR LegalNew Delhi (India)

Ian Cremer (United Kingdom)

Senior Technical OfficerValuation Sub-DirectorateTariff and Trade Affairs DirectorateWorld Customs OrganizationBrussels (Belgium)

Peter Eisenring (Switzerland)

Lic. oec. HSG, Swiss certified tax expertHead Group Tax and InsuranceRoche Basel (Switzerland)

Danny Houben (the Netherlands)

Global Transfer Pricing Manager Shell International BVThe Netherlands

Faculty at LLM programInternational Tax Center and IBFDLeiden and Amsterdam (the Netherlands)

Dr. Emmanuel Llinares (France)

Chair, Global Transfer Pricing PracticeSenior Vice PresidentNERA Economic ConsultingParis (France), Geneva (Switzerland)

Prof. Dr. Andreas Oestreicher (Germany)

Steuerberaterin (German Tax Advisor)Chair for Business Administration, Director of the Tax Division Faculty of Economic SciencesGeorg-August-Universität Göttingen (Germany)

Of Counsel, PwC (Germany)

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Dr. Stephanie Pfeifer (Germany)

Steuerberaterin (German Tax Advisor)Senior Manager (FF/I Fiscal & Finance / International)Daimler AGStuttgart (Germany)

Dr. Robert Risse (Germany)

Corporate Vice PresidentHead of Tax & Trade DepartmentsHenkel AG & Co. KGaADüsseldorf (Germany)

Antonio Russo (Italy/the Netherlands)

Partner and Head of Transfer PricingBacker & McKenzieAmsterdam (the Netherlands)

Dr. Barbara Schmid, MBA, MSc, MA, CIA (Switzerland)

Head Int. Trade Affairs & Customs RegulationsRoche Basel (Switzerland)

Caroline Silberztein (France)

Partner Baker & McKenzie Paris (France)

Former Head Transfer Pricing Unit Centre for Tax Policy and AdministrationOECDParis (France)

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Michel van der Breggen (the Netherlands)

Partner Financial Services Transfer PricingPwCAmsterdam (the Netherlands)

Isabel Verlinden (Belgium)

Global Transfer Pricing Leader Member of Global Tax Leadership TeamPartner International Tax and Transfer Pricing PwC Brussels (Belgium)

Non-Government Member EU Joint Transfer Pricing ForumBrussels (Belgium)

Oliver Wehnert (Germany)

EMEIA Transfer Pricing LeaderHead of Practice – GSAEYDüsseldorf (Germany)

Graeme Wood (United States)

Director, Global Taxes – Transfer PricingProcter&GambleCincinnati (United States)

Ruud Tusveld, LL.M. (the Netherlands)

Customs & International Trade advisorPartner, Leader EMEA Customs & International Trade GroupPwC Rotterdam (the Netherlands)

Lecturer at Masters Customs & Supply Chain complianceRotterdam School of Management – Erasmus UniversityRotterdam (the Netherlands)

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Lunches, Coffee Breaks, and DinnerThe course includes, every day, two coffee breaks and one lunch. A dinner is organized for the evening of Septemebr 23, 2015. Participants can join these events free of charge.

Course MaterialsThe participants are provided, at the beginning of the course, with a binder containing the presentations and the case studies discussed during the workshops.

Additionally, a USB stick containing further documents relevant for the course will be provided.

Course Level and PrerequisitesThe course starts at an intermediary level. Hence, it is suggested that participants have some experience in the field. No advanced preparation is required.

VenueThe course is held in Vienna at the WU campus (www.wu.ac.at/campus/en/), which is conveniently accessible by public transportation.

The address of the campus is:

Vienna University of Economics and Business (Wirtschaftsuniversität Wien, WU)Welthandelsplatz 11020 Vienna, Austria

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Course FeeThe course fee is 2,250.- Euro.

A 20% “early bird discount” is applicable to applications sent by May 31, 2015.

The course fee covers course participation, all course materials, lunches, coffee breaks and refreshments. Costs of travel and accommodation are not covered.

Questions and ContactFor any question regarding the attendance of the course, travel arrangements, payments, and other similar topics please contact Ms. Hedwig Pfanner (hedwig.pfanner@wu.ac.at).

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RegistrationPaymentYou will receive an invoice for the participation fee of 2,250.- Euro (or of 1,800.- Euro, in case of application of the “early bird discount”), which we ask you to transfer to the bank account specified in the invoice (payment deadline: September 1, 2015).

CancellationAny notification of cancellation of registration must be sent in writing to Ms. Hedwig Pfanner (hedwig.pfanner@wu.ac.at). In case of cancellation before August 21, 2015, the participation fee will be refunded. No refund can be made for cancellations received after August 21, 2015.

ApplicationPlease fill out the attached application form and submit it to Ms. Hedwig Pfanner (hedwig.pfanner@wu.ac.at).

We are looking forward to welcoming you to Vienna!

M. Lang / J. Owens / P. Pistone / A. Rust / J. Schuch / C. Staringer / A. Storck / R. Petruzzi

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I hereby submit my application for the Global Transfer Pricing Course (Advanced Topics) held from September 21 to September 25, 2015 in Vienna (Austria).

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Application Form