Transfer Pricing Regulation in the 2020 Landscape: Maximizing Opportunities and Overcoming Challenges
Transfer pricing presents notable challenges and opportunities for multinational entities. Significantly, the rising disputes and sweeping impact of recent tax reforms have continuously reshaped its regulatory landscape and resulted in an intensified scrutiny. However, with a keen understanding of and proper compliance with the rules, transfer pricing can be substantial in positioning a business both locally and globally.
In this LIVE Webcast, transfer pricing experts David Hutchings (The Brattle Group) and Robin Hart (CRA) will provide the audience with an in-depth analysis of transfer pricing regulations, as well as recent updates and developments surrounding the topic. As experts, David and Robin will also discuss the best practices to overcome the challenges while maximizing opportunities.
Some of the major topics that will be covered in this course are:
- Transfer Pricing Regulation in the 2020 Landscape: The Fundamentals
- Recent Trends and Developments
- The Impact of Global Tax Reform on Transfer Pricing
- Risks, Challenges, and Pitfalls
- Practical Tips and Strategies
- What Lies Ahead
The Brattle Group
Charles River Associates
- OECD Updates
- Taxation of the Digitalization of the Economy
- Focus on Pillar 1 as that is more TP-centric
- Action 13 expansion to developing countries
- Re-evaluating Country by Country reporting
- OECD and International updates
- OECD Financial transactions
- re-characterization in Canada and Australia
- US Updates
- IP Cases
- Amazon Case
- Facebook Case
- US Updates
- Stock compensation case
- Altera Case
- tech companies’ procedure-base objections to the regulation
- how to apply arm’s-length principle when there is no comparable (which may get us into allocation)
- Altera Case
Who Should Attend:
- Transfer Pricing Lawyers
- Tax Lawyers
- Transfer Pricing Advisers
- Transfer Pricing Managers
- Finance Executives
- Financial Reporting Officers
- Tax Managers and Directors
- Financial Auditors
David Hutchings, a principal in The Brattle Group’s Toronto office, specializes in conducting economic analysis in complex tax, securities, and antitrust matters. Having assisted experts and attorneys for both taxpayers and taxing authorities, he has extensive experience in tax disputes and transfer pricing matters. He testifies, supports experts, and leads case teams in analyzing and developing economic and financial evidence to support attorneys. Among his experience, Mr. Hutchings has focused on developing innovative economic analyses to assess the best method for transfer pricing, assessing the profitability of transactions, and investigating the business purpose doctrine.
David Hutchings, a principal in The Brattle Group’s Toronto office, specializes in conducting economic analysis in complex tax, securities, and …
Robin Hart is a Principal within CRA’s Transfer Pricing practice based in the San Francisco Bay Area. Robin is a highly regarded transfer pricing and tax economist with 18 years of experience serving clients in the life sciences, technology, and consumer products sectors. He has assisted taxpayers with their strategic objectives relating to the transfers and licensing of intangible property, alignment of supply chains, the establishment of high-value and shared service centers, and intercompany financing. Focused primarily on innovative Bay Area companies, Robin has executed on cross-border and domestic transactions involving cost-sharing and IP planning, post-acquisition integration, global BEPS alignment, the launch of new digital business models, and business restructurings. Prior to joining CRA, Robin was a Managing Director with Deloitte Tax in San Francisco.
Robin Hart is a Principal within CRA’s Transfer Pricing practice based in the San Francisco Bay Area. Robin is a …
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Method of Presentation:
General knowledge of transfer pricing
NY Category of CLE Credit:
Areas of Professional Practice
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About The Brattle Group
The Brattle Group answers complex economic, regulatory, and financial questions for corporations, law firms, and governments around the world. We have been retained by dozens of Fortune 500 companies and governments as consulting and testifying experts in litigations related to energy, finance, and litigation and regulatory support – including tax and transfer pricing disputes.
About Charles River Associates
Charles River Associates is a leading global consulting firm that offers economic, financial, and strategy expertise to major law firms, corporations, accounting firms, and governments around the world.
With proven skills in complex cases and exceptional strength in analytics, CRA consultants have provided astute guidance to clients in thousands of successful engagements. We offer litigation and regulatory support, business strategy and planning, market and demand forecasting, policy analysis, and risk management consulting.
Our success stems from the outstanding capabilities of our consultants, many of whom are recognized as experts in their respective fields; our close relationships with a select group of respected academic and industry experts; and from a corporate philosophy that stresses interdisciplinary collaboration and responsive service.
Headquartered in Boston, the firm has offices internationally.