The OECD’s BEPS: Impact on Transfer Pricing Landscape
Over the years, the Organization for Economic Cooperation and Development (OECD) continues to move forward with the implementation of its Base Erosion and Profit Shifting (BEPS) to effectively adapt with the rapidly evolving nature of international tax rules.
In order to succeed in this new riskier international taxation environment, it is important to have a complete understanding of the legal framework of BEPS and the possible implications it may create.
In this LIVE Webcast, a seasoned panel of thought leaders and professionals brought together by The Knowledge Group will present to the audience an in-depth analysis of the fundamentals as well as the significant impact of OECD’s BEPS on Transfer Pricing. Speakers will give highlights to the legal issues and insights of this significant topic.
Key topics include:
- Base Erosion and Profit Shifting (BEPS) - Legal Perspective
- Principles of the OECD's BEPS Initiative
- Changes to Transfer Pricing Arrangements and Documentation
- Impacts of BEPS on Transfer Pricing
- Recent Trends and Developments
- Remuneration from funding depends on control over risk
- Exercises Control over Risk Management
- Cash Box – Tangible Asset Example
- Financing Opportunity?
- Convenient FACTS?
- Arm's length assumptions?
Economics Partners, LLC
- Post-BEPS emphasis on value creation
- Capital, not functions, claims profit in the open market
- “Functions” have lost their function in TP
- Low substance entities
- The superiority and availability of transactional profit splits
- Capital-based profit splits
Who Should Attend:
- Taxation Lawyers
- International Tax Specialists and Managers
- Multinational Corporation CEOs
- Multinational Corporation Accountants
- International Treaty Specialists
- Finance Specialists
- Financial Risk Managers
- Tax Directors
- Transfer Pricing Personnel
Brad Rolph is the leader of our Tax Service Line for the Southern Ontario market and the National Transfer Pricing Leader for Grant Thornton in Canada. He offers over 20 years of experience helping multinational companies address their transfer pricing issues. Euromoney recognized Brad as one of Canada’s leading transfer pricing advisors in its Guide to the World’s Leading Transfer Pricing Advisers (2001, 2011, 2013, 2015). Brad was the first economist hired by any accounting firm in Canada to practice transfer pricing exclusively. He has been qualified as a transfer pricing expert in the Tax Court of Canada.
Brad helps his clients plan, implement and defend transfer pricing policies that strategically optimize tax-efficient supply chains. He has successfully defended transfer pricing polices under audit, at appeals and at competent authority. He has also negotiated and coordinated APAs. He provides litigation support and expert witness reports to law firms representing clients with transfer pricing matters.
Brad has served companies based in Canada, the United States, England, Ireland, Finland, France, Germany, Sweden, Saudi Arabia and Japan. He has dealt with issues in many industries including: Aerospace, Mining, Metals and Minerals, Transportation, Heavy Manufacturing, Steel, Utilities, Automotive, Chemical, Pharmaceutical, Electronic, Financial Services, Wholesale Trade and Consumer Goods. He also has extensive experience with Japanese trading companies and web-based businesses.
Brad Rolph is the leader of our Tax Service Line for the Southern Ontario market and the National Transfer Pricing …
Mr. Fernandez brings experience from a variety of roles and industries, having held positions in product development, finance, and marketing for energy, aerospace, telecommunications, and software companies. He specializes in transfer pricing, business and intangible property valuation, and other and valuation-related projects where he applies his understanding of technology and his economic analysis experience. He also has experience in business litigation cases involving patent infringement in the technology sector and in litigation support. In addition to his industry experience, he has extensive experience in the Latin American region.
Rodrigo has worked on a broad array of transfer pricing and economics consulting engagements, including transfers of intangible and tangible business property, technology buy-ins, cost sharing agreements, services transactions, and the structuring of intangible property holding companies and operating companies. Additionally, he has worked on intangible property and business valuation projects, valuing firms in oil field services, energy, software, semiconductors, medical devices, packaging, metals, auto parts, and telecommunications.
Prior to joining Economics Partners, Rodrigo was a Director with Duff & Phelps, and prior to that he was a consultant at Analysis Group. Before working as a consultant, Rodrigo held a variety of operations roles in technology-intensive industries. He was a systems engineer at Ball Aerospace, performed energy-related product development with Redstone Engineering, was involved in IT strategy and pricing strategy at Qwest Communications, and also worked with several small software companies.
Mr. Fernandez brings experience from a variety of roles and industries, having held positions in product development, finance, and marketing …
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Method Of Presentation:
Experience in taxation
NASBA Field of Study:
Taxes - Technical
NY Category of CLE Credit:
Areas of Professional Practice
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About Economics Partners, LLC
Founded to address a market need. We provide non-leveraged, partner-driven, finance and economics services to large corporate tax departments.
We handle all of the applied finance and economics needs of our corporate tax and law firm clients.
These include restructuring-related valuation and economic analyses, in both controversy and planning settings. We act as expert witnesses. We negotiate audit settlements and advance pricing agreements between governments and taxpayers. We price, document, and defend our clients’ most sensitive intercompany transactions. We provide economic analysis in support of our clients’ negotiations with governments regarding tax incentives.
In contrast to most of our competitors, we are committed to maintaining a Senior:Junior staff ratio of 1:1. This is critical to our partner-driven service model, our staff apprenticeship model, and our quality control procedures.
We are thought leaders in the areas of intangible asset valuation, transfer pricing, and general valuation theory. Our white papers and publications have gained notoriety around the world, and are recognized by corporate clients, lawyers, and tax authorities as offering real advances. Our valuation models are transparently available to our clients, allowing us to work jointly with them on many of their most important valuation and transfer pricing matters.