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CORPORATE TAX SUMMIT LARS VON JESCHE STANISLAVA MANOLOVA DONATA KOREN Partner, International Corporate Tax Tax Manager Senior Lead of Tax Team BDO PORR AG Zalando

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CORPORATE TAX SUMMIT LARS VON JESCHE STANISLAVA MANOLOVA DONATA KOREN Partner, International Corporate Tax Tax Manager Senior Lead of Tax Team BDO PORR AG Zalando 17-18 OCTOBER 2019 FRANKFURT, GERMANY 6th ANNUAL CORPORATE TAX SUMMIT LARS VON JESCHE STANISLAVA MANOLOVA DONATA KOREN Partner, International Corporate Tax Tax Manager Senior Lead of Tax Team BDO PORR AG Zalando EDUARDO R. FLÖRING JR. LUIS CARRILLO MARK JOHNSON Head of Transfer Pricing Senior Director – Tax & Transfer Pricing Solutions Co-Head of Unit, Tax Certainty / CbC Reporting CHAIRMEN Theo Müller Group Bureau Van Dijk – A Moody’s Analytics OECD Company RAFFAELE PETRUZZI HARM J OORTWIJN BRIGITTE BAUMGARTNER Managing Director Senior Tax Structuring, Reporting and Compliance Independent Transfer Pricing Expert WU Transfer Pricing Center Whirlpool TP Baumgartner KSENIJA CIPEK ANDREAS RIEDL MARIA GRIGORYEVA Head of Tax Risk Analysis Partner Transfer Pricing & Head of TP Technology Senior Manager Ministry of Finance Croatia WTS TPA GlobaI XAVIER CAMPS MARK HOUTZAGER PHILIP DE HOMONT Senior Tax Manager EMEA Tax Leader Associate Director Electronic Arts (EA) Starbucks NERA Economic Consulting MARC MOKRAB FURHERR GEBHARD ÓSCAR BERTRÁN Global Head of Tax Auditor and Tax Advisor Partner Technicolor LeitnerLeitner GmbH Cuatrecasas SPEAKERS KATE BUSHBY XAVIER XIVILLE YVES HERVE International Tax Lead Partner, Lawyer, Economist Managing Director TransferWise Cuatrecasas NERA Economic Consulting SOPHIA REISMANN EMINE CONSTANTIN PAUL DALY Senior Tax Expert – Global Transfer Pricing Global Head of Accounting & Tax Partner, Head of Transfer Pricing OMV TMF Group BDO DIRK ELBERT WOLFGANG KLOSTER Partner Partner BDO BDO • Transfer Pricing, User Participation, and Attribution of Profits • Aligning tax KPIs/targets with the overall corporate to Virtual Permanent Establishments • Tax function automation • CbCR, SAF-T, e-invoicing – exploring digital initiatives • A detailed look into BEPS and MLI • International tax disputes – MAP, Arbitration, APAs KEY TOPICS • Staff turnover and education – building an effective tax team for the future • Recent developments in ICAP pilot PLATINUM SPONSOR GOLD SPONSOR SILVER SPONSOR BRONZE SPONSOR Brand colors 01 CMYK Burgundy Coral CMYK 0 100 0 85 CMYK 0 73 32 0 RGB 70 0 29 RGB 255 90 96 #46001d #f f5a60 Pantone 1817 U Pantone 1787 U Pantone 504 C Pantone 1785 C AGENDA THURSDAY, DAY 1 #UNGCTS 08:15 REGISTRATION & MORNING COFFEE 13:00 INTERACTIVE LUNCH TABLE DISCUSSION Participant will be discussing pre-selected topics in small groups during 08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON lunch. Each table is assigned with a moderator to keep the discussion energetic and interesting 09:00 Transfer Pricing, User Participation, and Attribution of Profits to Virtual Permanent Establishments SUMMARY OF THE TABLE DISCUSSION • The changing environment Continued in the conference room, a short summary of the discussion will • Case study be shared by table moderators • What will the future bring 14:20 International tax disputes – MAP, APAs, arbitration RAFFAELE PETRUZZI • Recent developments and practical cases Managing Director • Challenges in negotiation WU Transfer Pricing Center • Reducing the time of resolution 09:30 Data security • Disputes involving two or more territories • In-house guidelines EDUARDO R. FLÖRING JR. • Data Protection Directive Head of Transfer Pricing • Exchange of information, joint audits Theo Müller Group • Providing data to third partie 14:50 Recent developments in ICAP pilot BRIGITTE BAUMGARTNER • Current status Independent Transfer Pricing Expert • What are the drivers? TP Baumgartner • Covered risks • The process 10:00 PANEL DISCUSSION Topic: Tax Proposals MARK JOHNSON • Common Consolidated Corporate Tax Base (CCCTB) Co-Head of Unit, Tax Certainty / CbC Reporting OECD • VAT Definitive Regime • Digital Services Tax 15:30 PANEL DISCUSSION Moderator: Topic: Working together – improving communication between enterprises LARS VON JESCHE | BDO and policymakers What are the issues facing MNEs on recent tax laws? How to improve Panelists: communication between MNEs and tax administrators? Overview of CHRISTINA LEOMY-VOIGT | ATOZ Tax Advisers globalization and market consolidation EMINE CONSTANTIN | TMF Group Moderator: RAFFAELE PETRUZZI | WU Transfer Pricing Center KSENIJA CIPEK | Ministry of Finance Croatia, Tax Administration 10:40 COFFEE & NETWORKING BREAK Panelists: KATE BUSHBY | TransferWise 11:10 Global Mobility – Managing International Tax Risk ÓSCAR BERTRÁN | Cuatrecasas • Why is it important • Trends VIOLA BOGNAR | Vienna Insurance Group • The Bigger Tax Impact • Key considerations 16:10 COFFEE & NETWORKING BREAK PAUL DALY WOLFGANG KLOSTER Partner, Head of Transfer Pricing Partner 16:40 Thema Structural procedure for DEMPE analysis • DEMPE Analysis embedded in value contribution analysis BDO BDO AG • Slicing DEMPE methodological procedure 11:30 Exploring digital initiatives (SAF-T vs. Live Reporting) • Identifying routine DEMPE contributions • The evolution of digitization within tax world YVES HERVE • Challenges and benefits of digitization Managing Director • Digitization trends in EMEA, APAC, and LATAM NERA Economic Consulting • What is next? EMINE CONSTANTIN 17:10 Building an effective tax team for the future Global Head of Accounting & Tax • Evolving focus of the tax team TMF Group • Tax in a mission driven start up • High performance in a hyper growth environment 12:00 New horizontal monitoring-programme in Austria KATE BUSHBY • Co-operative procedure between taxpayer & tax administration International Tax Lead (replaces tax audit) TransferWise • Prerequisites for participation (i.e. Tax Compliance Management System) • Benefits for taxpayers & tax administrators 17:40 Aligning tax KPIs/targets with the overall corporate KPIs • Lessons learned • Are taxes managed properly? • Does Tax operate in the most efficient way possible? FURHERR GEBHARD • Job satisfaction and recognition measures Auditor and Tax Advisor • Outsourcing compliance LeitnerLeitner GmbH MARC MOKRAB 12:30 Compliance Risk Management: Prevention vs. Repression Group Head of Tax • Legislation and CRM System Technicolor • Managing data • Prevention of Tax Fraud 18:10 CHAIRPERSON’S CLOSING REMARKS, END OF DAY 1 • Possibilities of New Technologies in Tax Administrations KSENIJA CIPEK Head of Tax Risk Analysis Ministry of Finance Croatia, Tax Administration UNIGLOBAL 2019 tel. +420 226 220 400 fax +420 226 220 444 www.uni-global.eu AGENDA FRIDAY, DAY 2 #UNGCTS 08:15 MORNING COFFEE 12:50 NETWORKING LUNCH 08:50 WELCOME & OPENING REMARKS FROM THE CHAIRPERSON 13:50 TP Technology implementation • Setting a TP digitalization strategy 09:00 Tax function automation • Effectively implementing TP technology: pitfalls & learnings • Technology = compliance + consistency • Use cases for data & analytics in TP • RPA, Tax ERP, AI • Improving audit efficiency and effectiveness SOPHIA REISMANN Senior Tax Expert – Global Transfer Pricing STANISLAVA MANOLOVA OMV Tax Manager PORR AG 14:20 Managing complexity in transfer pricing audit • How to reduce risk in the Transfer Pricing tax audit? 09:30 Transformation of the TP Function • Preemptive measures to avoid a tax audit • Trends regarding the digitization of the TP function • Anti-tax audit documentation • Standardization vs. Individualization • Managing multi-country tax audits • How to be prepared: process, data and personnel • Post-tax audit measures ANDREAS RIEDL XAVIER XIVILLE Partner Transfer Pricing & Head of TP Technology Partner, Lawyer, Economist WTS Cuatrecasas 10:00 Fit for future: A refined approach to tax risk management ÓSCAR BERTRÁN • Value chain analysis for risk monitoring and reporting Partner • Tax controversy decision-making Cuatrecasas • Tax technology for full risk control MARIA GRIGORYEVA 14:50 PANEL DISCUSSION Senior Manager Topic: ’Addressing the Tax Challenges of the Digitalization of the Economy’ TPA Global by OECD Moderator: 10:30 COFFEE & NETWORKING BREAK ROSS ROBERTSON | BDO 11:00 Taxation of the digital economy Panelists: • How to adapt the concept of value creation to the digital environment? • Digital Services Tax (DST) and other proposals YVES HERVEE | NERA Economic Consulting • Tackling BEPS in the digital economy BRIGITTE BAUMGARTNER | TP Baumgartner • Corporate taxation of Significant Digital Presence REINOUT DE BOER | Stibbe XAVIER CAMPS DONATA KOREN Senior Tax Manager Senior Lead of Tax Team 15:30 COFFEE & NETWORKING BREAK Electronic Arts Zalando 11:30 Integrating tax technologies 16:00 Solving Hard-to-Value Intangibles • Improve tax efficiency • Definition – is there any easy-to-value intangible? • Starbucks’s path towards a more efficient compliance process • BEPS-challenges: The issue of ex-post adjustments • Lessons learned • Methodological approaches to avoid adjustments MARK HOUTZAGER PHILLIP DE HOMONT EMEA Tax Leader Associate Director Starbucks NERA Economic Consulting 12:00 The New World of Cost Contribution Agreements 16:30 Management of the ETR to reduce ETR • Definition of Cost Contribution Agreements & Indirect Charge Method • Tax Risk monitoring • CCAs after BEPS • Backward and forward-looking ETR • The new German decree on CCAs • Tax policy parameters • Changes to be implemented before 2020 HARM J OORTWIJN Senior Tax Structuring, Reporting and Compliance DIRK ELBERT Whirlpool Partner BDO 17:00 CLOSING REMARKS & CHAIRPERSON’S SUMMARY 12:20 Under the Microscope: Big Data and Digitalization of Tax Administrations for Audit Case Selection 17:10 END OF THE SUMMIT • Big data • Sources of information • Current Digital landscape of tax administrators • Conclusions LUIS CARRILLO Senior Director – Tax & Transfer Pricing Solutions Bureau
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