Main Conference: 15 & 16 June 2021 Workshops: 17 June 2021 Virtual Conference BST/UTC+1 Time Zone

THE WORLD’S LEADING INDEPENDENT TRANSFER PRICING FORUM

Inspiration Networking 100+ Speakers 450+ Attendees 30+ Presentations & Panels 70% Corporate Delegates 6 Workshops & Briefings 20+ Industries Represented

Matt Andrew Janine Juggins Jens Svolgaard Karine Halimi-Guez Kurt Wulfekuhler John C. Hughes OECD UNILEVER BOLT FEDEX VERIZON IRS

TP Minds @TPSummit https://informaconnect.com/tp-minds-international-conference/ #TPMINDS21 EVENT SCHEDULE SPONSORS AND EXHIBITORS LEAD PARTNER Main Conference: 15 & 16 June 2021 Workshops: 17 June 2021

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MEDIA PARTNER

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 2 MEET 100+ TP LEADERS, ADVISORS & POLICY MAKERS

Adly Adly Rachit Agarwal Israel Ajayi Head of Tax – BU West Europe (UK & Ireland) Transfer Pricing Director Lead, International Tax &Transfer Pricing AB INBEV DLA PIPER (Oil & Gas Division) NIGERIA FEDERAL INLAND REVENUE SERVICE

Önder Albayrak Ken Almand Guilherme Alves Head of Transfer Pricing for Strategy & Operations - Partner, Transfer Pricing, London, United Kingdom South America Tax Manager Head of Tax Benelux at Sanofi BDO LOUIS VUITTON SANOFI

Matt Andrew Dr Joshua Bamfo Jean-Louis Barsac Head of the Tax Treaty, Transfer Pricing, and Financial Partner & Head, Transfer Pricing Group Head of Tax Transactions Division ANDERSEN NIGERIA VALEO OECD

Adnan Begic Abhijay Bhatia Elena Blanque Head of Transfer Pricing, Asia-Pacific Director - Transfer Pricing Operations US Exec. V.P. of Finance and Global Head of Tax MICHELIN CONVATEC GRUPO ANTOLIN

Ernest Breitschwerdt Barend Broen Martin Brooks CFA –Senior Credit Product Specialist Transfer Pricing Director Senior Adviser S&P GLOBAL MARKET INTELLIGENCE SHELL FTI CONSULTING

Monica Calijuri Luis Carrillo Cintli Chacon Economist - Sector Lead Specialist, Tax Administration Transfer Pricing Director Global Head of Transfer Pricing IADB MOODY’S PUMA ENERGY

Ken Chan Debora Correa Talutto Matteo Crispi Global Head of Tax Senior Tax Manager Head of Global International Tax and Transfer Pricing FINASTRA VERITAS BARILLA

Paul Daly Bo Darling Larsen Bernardo Danesi Transfer Pricing Partner Head of Competent Authority BDO DANISH COMPETENT AUTHORITY NERA ECONOMIC CONSULTING

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 3 MEET 100+ TP LEADERS, ADVISORS & POLICY MAKERS

Juan Dosal Blanco Hany Elnaggar Monica Erasmus-Koen Transfer Pricing Practice Leader, Netherlands Head of Tax for Middle East; JIACC Tax Commission Managing Partner Transfer Pricing RSM Member TAXTIMBRE NISSAN

Mauro Faggion Antoine Faure Mohamed Fayçal Charfeddine Policy Officer Partner Group Head of Tax EUROPEAN COMMISSION DLA PIPER AUJAN COCA-COLA

Lucia Fedina Ainsley Gaddis Hans Geluk Director, Transfer Pricing Transfer Pricing Controversy Leader Global Transfer Pricing Manager CBRE GE HEALTHCARE DANONE

Rutger Hafkencheid Karine Halimi-Guez Enrique Guzman Counsel; Tax Layer Managing Director, Tax Transfer Pricing Manager LOYENS & LOEFF FEDEX HITACHI EUROPE

Catherine Harlow Gareth Harrison Yves Hervé Head of Transfer Pricing Head of Tax Managing Director ASTRAZENECA AIRTEL AFRICA NERA ECONOMIC CONSULTING

Ramon Hogenboom John C. Hughes Anton Hume Global Transfer Pricing & Dutch Corporate Tax Manager Director, APMA Tax Partner, Corporate International Tax JACOBS DOUWE EGBERTS COFFEE INTERNAL REVENUE SERVICE, U.S. BDO

Janine Juggins Marc Kanter Ted Keen EVP Global Tax Director of Transfer Pricing Managing Director UNILEVER AKZONOBEL DUFF & PHELPS

Stephan Kraan Lukasz Kubicki Pramod Kumar Senior Associate; Tax Advisor Head of International Tax Global Tax Director - Beyond Tires, Fenner Buisness Lines LOYENS & LOEFF OERLIKON MICHELIN NORTH AMERICA

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 4 MEET 100+ TP LEADERS, ADVISORS & POLICY MAKERS

Akin Kumru Martin Lagarden Andrea Lee Principal Director, Europe Market Lead Head of Global Transfer Pricing Executive Assistant to CFO/CRO HENKEL ERSTE GROUP

Michael Lennard Chris Liu Christoph Ludwig Chief, International Tax Cooperation; Financing for Managing Director Partner; Tax - Transfer Pricing Development Office FTI CONSULTING WARTH & KLEIN GRANT THORNTON UNITED NATIONS

Charles Marais Norzilah Mat Arbak Sarah Meadows Partner; Head of Transfer Pricing, Netherlands Deputy Director of Services Audit Division Deputy Head of Tax GRANT THORNTON INLAND REVENUE BOARD MALAYSIA IMPERIAL BRANDS

Miguel Navas Yordan Nenkov Andy Neuteleers VP of Tax Head of Investment Tax Partner Transfer Pricing Belgium & Luxembourg CABIFY PARTNERS GROUP TIBERGHIEN ECONOMICS

Michael Nixon Duncan Nott Warren Novis Senior Advisor, TTP Unit Transfer Pricing Partner Transfer Pricing OECD RSM OPENTEXT

Mary O’ Leary Wade Owen Manisha Pande Tax Lawyer | Tax Technology Lead at Vizor | Senior Director, Global Transfer Pricing Transfer Pricing Director Tax & Digitalisation VISA BAKER HUGHES VIZOR

Marta Pankiv Erica Perry Katarina Petovska Director of Tax Partner, Transfer Pricing Lead of Global Transfer Pricing Planning & Operations TRICENTIS KPMG DELL TECHNOLOGIES

Amanda Pletz Marike Rabie Vineet Rachh Associate Director Head of Transfer Pricing Associate Director – Taxes NERA ECONOMIC CONSULTING STEINHOFF INTERNATIONAL PROCTOR & GAMBLE

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 5 MEET 100+ TP LEADERS, ADVISORS & POLICY MAKERS

Alexandra Readhead Zara Richie Brad Rolph Lead, Tax and Extractive Industries Australia National Leader, Transfer Pricing Services Canada National Practice Leader; Transfer Pricing INTERGOVERNMENTAL FORUM ON MINING, MINERAL, BDO GRANT THORNTON METALS AND SUSTAINABLE DEVELOPMENT (IGF)

Cesar Salagaray Don Shackley Seema Sharma Partner Head of Transfer Pricing Head of Tax DLA PIPER BURBERRY NETWORK INTERNATIONAL PLC

Mark Shuette Ednaldo Silva Anju Singh Transfer Pricing National Practice Leader; Global Transfer Founder & Director National Leader - Operational Transfer Pricing Pricing Centre of Excellence Leader ROYALTYSTAT RSM US BDO

Tine Slaedts Bernardo Solano Ruth Steedman Partner, Transfer Pricing Senior Partner Senior Managing Director TIBERGHIEN ECONOMICS BASEFIRMA FTI CONSULTING

Marcus Stelloh Nick Stevart Paul Sutton Partner, Head of Transfer Pricing, Transfer Pricing Director Co-Founder Johannesburg, South Africa KPMG LCN LEGAL BDO

Jens Svolgaard John Thurstans Louisa Tlale Global Head of Tax, Treasury & Internal Audit Senior Manager, International Tax Head of Transfer Pricing & International Tax BOLT VODAFONE SASOL

Andrea Tolley Jere Tormanen Vanessa Toro Partner, Head of Transfer Pricing Corporates Head of Tax VP Global Transfer Pricing KPMG BATA BRANDS UNILEVER

Heleen Van Baelen Harmen van Dam Kenny Van Tulder Senior Manager, Transfer Pricing Partner Senior Manager TP & Valuations TIBERGHIEN ECONOMICS LOYENS & LOEFF TIBERGHIEN ECONOMICS

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 6 MEET 100+ TP LEADERS, ADVISORS & POLICY MAKERS

Dominic Vines Michael W. Wallace Jared Walls Team Leader (Financial TP); Delegated Competent Managing Director - Tax Consulting - Partner Authority Global Practice Lead VALENTIAM GROUP HMRC ACCENTURE

Gerben Weistra Joel Wilpitz Kurt Wulfekuhler Partner Director of Global Transfer Pricing Director, Transfer Pricing ECTACON SAZERAC COMPANY VERIZON

Andrew Wynn Managing Director FTI CONSULTING

For full list and the latest speaker updates please visit our Speakers’ Page online.

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 7 DAY 1 | TUESDAY, 15 JUNE 2021

Ken Almand Zara Richie Partner, Transfer Pricing, Australia National Leader, London, United Kingdom Transfer Pricing Services BREAKFAST BRIEFING - Global Transfer Pricing Developments Roundup - Americas, Europe, Africa BDO BDO and Asia-Pacific 08:30 - Mark Shuette Marcus Stelloh 09:25 This pre-conference breakfast briefing will set the scene for the discussions taking place over the two days of our main summit. Transfer Pricing National Partner, Head of Transfer Delegates will receive a full briefing on the latest transfer pricing developments across the globe by a distinguished panel with expertise Practice Leader; Global Pricing, Johannesburg, in key geographies including the Asia-Pacific, The Americas and Continental Europe. Full panel line-up to be announced soon. Transfer Pricing Centre South Africa of Excellence Leader BDO BDO

Ruth Steedman 09:25 Chair’s Opening Remarks Senior Managing Director FTI CONSULTING

Matt Andrew Head of the Tax Treaty, Transfer Pricing, and Financial 09:30 Annual OECD Keynote Speech Transactions Division OECD

Matt Andrew Michael Lennard PANEL DISCUSSION Head of the Tax Treaty, Chief, International Tax Global TP Policy Developments - State of Play and Policy Makers’ Outlook Transfer Pricing, and Cooperation; Financing This policy makers panel will examine and debate: Financial Transactions for Development Office • How tax authorities are being advised to tread the balance between raising badly needed revenue and allowing hard hit businesses Division UNITED NATIONS to recover OECD 10:00 • Digital services tax/ Pillar 1 – where do we go from here? Mauro Faggion • Pillar 2 – does the US have the answer? Dominic Vines Policy Officer • How do governments maintain the excellent cooperation exemplified within the OECD discussions in the coming years when revenue is so badly needed in every jurisdiction? Team Leader (Financial EUROPEAN • What do policy makers think about some form of tax levy for upskilling tax authorities so that the implementation of BEPS, Pillar 1 TP); Delegated COMMISSION and Pillar 2 is consistent around the globe Competent Authority HMRC

11:00 Networking - Lounge Break or 1:2:1 Video Meetings

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 8 Michael Nixon Adnan Begic Senior Advisor, TTP Unit Head of Transfer PANEL DISCUSSION OECD Pricing, Asia-Pacific Rising Out of COVID – How Should Corporations and Fiscs Respond MICHELIN This session will aim to share practical experience and decisions taken by business in relation to their transfer pricing policies during Andrew Wynn COVID and beyond including: Managing Director Don Shackley 11:15 FTI CONSULTING Head of Transfer Pricing • Changes or otherwise to policies and time frames involved BURBERRY • Documentation prepared to support changes Moderator: • Preparations for controversy management post COVID • Approach to benchmarking for the COVID period Ruth Steedman • Experience with tax authorities regarding requests for amendments to unilateral and bilateral APAs Senior Managing Director FTI CONSULTING

12:00 Networking - Lounge Break or 1:2:1 Video Meetings

Lunch Break & Themed Roundtables (Discussion Groups) Join a table of 20 of your peers over lunch and participate in the informal discussions (sandwich in hand!) on key areas transfer pricing and international taxation. Our themes tables cover a diverse range of topics. 12:15 From niche areas of interest to the “big ticket” debates of the day, we are sure you will find these highly valuable opportunities to learn, network and get to know other attendees. Plus! You can now collect free Amazon Gift vouchers for attending particular tables during this session! So keep an eye out for the tables that will keep on giving even after you leave the room. Gift voucher available for the first 20 delegates to join the table. Dropped directly onto your digital goodie bag when you are in our virtual platform.

TABLE 1 TABLE 2 TABLE 3 TABLE 4 INFORMAL SESSION INFORMAL SESSION INFORMAL SESSION INFORMAL SESSION Financial Transactions Discussion Group Intangible Asset Valuation Discussion Intercompany Agreements DAC 6 Discussion Group In February 2020, the OECD published the Group Join this lunch roundtable to exchange views on DAC 6 - The Unbearable Lightness of the TP report Transfer Pricing Guidance on Financial Transfer pricing litigation often revolves around the practical approaches to intercompany agreements, Hallmarks! In this lunch session, Andy Neuteleers Transactions. The update UN Practical Manual valuation of intangible assets. The OECD Transfer and to pick the brains of senior lawyers at LCN of Tiberghien economics, will share his real life on Transfer Pricing (published in April 2021) now Pricing Guidelines clearly state that a valuation Legal. We will explore key questions challenging experiences in assessing DAC6’s TP hallmarks. also includes a separate chapter on Intragroup of intangible assets for purposes is practitioners such as: How can MNEs implement The session will be based on a thorough analysis Financial Transactions. Join this lunch roundtable “not determinative” for transfer pricing purposes. their TP policies legally, without creating vast of discussions Andy held with peers in various to exchange views on the practical impact of this How should transfer pricing practitioners bridge amounts of lawyerish gobbledygook?; What are countries on country-specific differences in new guidance, including changes already seen this divide between valuation for accounting and the real lessons from Coca-Cola? (apart from the interpretation, and a deep-dive study of the in practice and the implications for day-to-day TP purposes, especially where “hard-to-value unintelligible arguments about economic theory?); concepts underlying the regulation (rendering the transfer pricing and treasury operations. Have intangibles” are involved? Join Duff & Phelps’ TP Which contractual terms are tax authorities most latter sometimes to become absurd/unbearable)… you already looked at you policies following the valuation experts for a roundtable discussion to likely to focus on in a TP audit?; What should we make your own informed conclusion after new guidance? Have you made any changes to find out more. do if we have large gaps in our intercompany this session and feel free to share your own 12:20 existing arrangements as a result? Are you talking agreements? Or if we know our agreements don’t experiences with your peers in a conversational to your treasury support? Join a select group of Ted Keen match our TP policies?; How can we ‘future proof’ environment. you colleagues to get the inside track on how our intercompany agreements?; How should Managing Director businesses are responding and take away practical we manage agreements as part of ongoing Andy Neuteleers DUFF & PHELPS tips from other heads of TP in an informal and operational transfer pricing?. A thought provoking Partner Transfer Pricing Belgium & conversational environment. discussion, not to be missed! Luxembourg TIBERGHIEN ECONOMICS Gerben Weistra Paul Sutton Partner Co-Founder ECTACON LCN LEGAL

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 9 TABLE 5 TABLE 6 TABLE 7 INFORMAL SESSION INFORMAL SESSION INFORMAL SESSION Multi-(TP) Process Automation – E.U. State Aid Discussion Group Structuring and Onshoring of IP Visualising the End State The recent Amazon EU State Aid decision includes Join this lunch roundtable for what is bound to be The international dialogue on direct tax automation many important transfer pricing points that an interactive and interesting discussion on the is much more mature than even 3 to 5 years ago. could help you in defending your transfer pricing challenging matter of structuring and onshoring of Companies are actively exploring automation positions. It, however, also highlights areas where IP from a Transfer Pricing perspective. Speakers options, or have automated at least one tax transfer pricing positions are at risk. During the and delegates will share experiences on key TAKE AWAY MORE process. But, tax automation has been very State Aid lunch round table Harmen van Dam, head issues such as key control (DEMPE) functions, the THAN JUST CUTTING topical in the past, whereas transforming from a of Loyens & Loeff’s 45 transfer pricing experts consequences of mismatches between legal and rather manually-orientated tax function to a data (including litigators) intends addressing the details economic ownership of the IP, treatment of hard- EDGE KNOWLEDGE driven, digitally-enabled tax function requires of the General Court’s Amazon decision, its impact to-value intangibles and the possibility of obtaining more integrated thinking (strategy). One of the on discussions and disputes with European tax certainty upfront by way of tax rulings. We look WITH YOU AT THE challenges around aiming for an integrated authorities, the impact on discussions about forward to having you participate in this highly END OF YOUR LUNCH approach is trying to visualise what the end state uncertain tax positions with your statutory topical discussion group. should look like and how tax fits within the wider auditors, the areas were you could improve the TIME SESSION. strength of your transfer pricing documentation, automation projects within the company. In this Charles Marais and the likelihood of new State Aid transfer pricing lunch roundtable we would like to exchange views Partner; Head of Transfer Pricing, on concepts like user journeys (the end users cases in the future. Netherlands should be at the center of the digital conversation), Be one of the first 20 delegates to challenges around thinking (digitally) big, but Harmen van Dam GRANT THORNTON take a seat at your chosen lunch acting small, digital-symbioses with the Finance Partner table and automatically receive an community, and more. Draw on the practical LOYENS & LOEFF learnings and experience of the roundtable e-Voucher from Amazon! participants and exchange your views. See T&Cs. Monica Erasmus-Koen Managing Partner Transfer Pricing TAXTIMBRE

Ramon Hogenboom Global Transfer Pricing & Dutch Corporate Tax Manager JACOBS DOUWE EGBERTS COFFEE

Hans Geluk Global Transfer Pricing Manager DANONE

13:00 Networking - Lounge Break or 1:2:1 Video Meetings

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 10 PANEL DISCUSSION Sarah Meadows Adly Adly Evolving Business Models – How Can TP Professionals Manage Change Deputy Head of Tax Head of Tax – BU West IMPERIAL BRANDS Europe (UK & Ireland) The world is changing and business models are changing too. Technology is redefining not only how companies do business, but AB INBEV what businesses they are in. Customers are defining the strategies and delivery models of those companies serving and supplying 13:15 them. New supply chains are emerging in response to cost constraints, trade disruption, COVID and digitalization. Corporate social Katarina Petovska responsibility and sustainability agendas are forcing companies to rethink their value chains and operating models. M&A activity Lead of Global Transfer Moderator: is also driving the pace of change, as companies look to strengthen their product portfolios and supply chains, as well as access Pricing Planning & Erica Perry new markets, customers and data. This is all happening against a backdrop of ongoing change in the international tax landscape Operations Partner, Transfer Pricing and increased tax authority scrutiny. This session will cover examples of business model transformation and discuss how TP DELL TECHNOLOGIES KPMG professionals can best navigate these changes.

14:00 Networking - Lounge Break or 1:2:1 Video Meetings

Katarina Petovska Jens Svolgaard Lead of Global Transfer Global Head of Tax, Pricing Planning & PANEL DISCUSSION Treasury & Internal Operations Audit Pillar 1 Developments – How is Industry Stepping up to the Challenges DELL TECHNOLOGIES 14:15 There continues to be great focus, and great uncertainty, on the development of Pillar 1 of the OECD response to the Tax Challenges BOLT Arising from Digitalisation. Our panel will reflect on the current status and considerations in light of recent and prospective Moderator: developments. Barend Broen Paul Daly Transfer Pricing Director Transfer Pricing Partner SHELL BDO

15:00 Networking - Lounge Break or 1:2:1 Video Meetings

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To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 11 STREAM A STREAM B STREAM C STREAM D PANEL DISCUSSION PANEL DISCUSSION PANEL DISCUSSION WORKING GROUP Pillar 2 and the Global Minimum Tax - Documentation and CBCR Mutinational Under Pressure - The Future Tax Transformation, Transparency, and Latest Developments of Tax Disputes After Digital Services Tax Big Data Analysis Industry panellists will discuss the impact of This panel comes together to discuss tax Catherine Harlow Pillar 2, which involves the development of new transformation and the digitalization. The global minimum tax rules, and whether this will Head of Transfer Pricing Marta Pankiv discussion will focus as much on people and be an effective means to prevent tax competition ASTRAZENECA Director of Tax processes as on the technological transformation between countries and a race to the bottom so TRICENTIS underpinning the rapid evolution of the tax far as the collection of tax revenues by fiscs is Warren Novis function. Areas under examination include: Dealing concerned. What does this mean for the future Transfer Pricing Marc Kanter with increased burden of tax administration on of transfer pricing? What are the implications for tax departments; Increasing transparency and OPENTEXT Director of Transfer Pricing intragroup trading? What will the U.S. position be? improving efficiency of tax operations; Designing These and many other questions will be explored AKZONOBEL and defending a successful tax technology by our panel. Lukasz Kubicki strategy; Data issues in improving the consistency Head of International Tax Nick Stevart of compliance processes; Automation and Pramod Kumar OERLIKON Transfer Pricing Director streamlining of tax processes. Global Tax Director - Beyond Tires, KPMG Fenner Buisness Lines Louisa Tlale Karine Halimi-Guez MICHELIN NORTH AMERICA Head of Transfer Pricing & Erica Perry Managing Director, Tax International Tax Partner, Transfer Pricing FEDEX 15:15 Alexandra Readhead SASOL KPMG Lead, Tax and Extractive Industries Manisha Pande INTERGOVERNMENTAL FORUM ON Moderator: Transfer Pricing Director MINING, MINERAL, METALS AND Andrea Tolley BAKER HUGHES SUSTAINABLE DEVELOPMENT Partner, Head of Transfer Pricing (IGF) Corporates Luis Carrillo KPMG Transfer Pricing Director Jean-Louis Barsac MOODY’S Head of Tax VALEO Ken Chan Global Head of Tax Jere Tormanen FINASTRA Head of Tax BATA BRANDS Michael W. Wallace Managing Director - Tax Consulting - Global Practice Lead ACCENTURE

Akin Kumru Principal Director, Europe Market Lead ACCENTURE PRESENTATION 16:00 Networking Lounge Break and Q&A

16:15 Chair’s Closing Remarks

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 12 DAY 2 | WEDNESDAY, 16 JUNE 2021 BREAKFAST BRIEFING Royalty Rates: Lessons from Coca-Cola In this topical broadcast, veteran Economist, Dr Ednaldo Silva of RoyaltyStat shares his observations on the large 10 bn USD Coca-Cola litigation and why this might be at odds with established economic principles. The session will analyse key points of this precedent-setting case involving royalty rates and the consequences of bypassing Ednaldo Silva 08:30 - external license agreements. With his usual intellectual rigour, Dr Silva will explain the effects of the U.S. Government and Coca-Cola’s failure to produce a reasonableness Founder & Director 09:15 test based on license agreements and the inconsistency of this approach. He will draw key lessons for MNEs and explain the policy implications of the need to determine fact-or-transactions based royalty rates or face higher hazards of litigation or higher risk of large unanticipated additional income tax liabilities connected with deemed ROYALTYSTAT unreported royalty income.

09:15 Chair’s Opening Remarks

Debora Correa Talutto Abhijay Bhatia Senior Tax Manager Director - Transfer PANEL DISCUSSION VERITAS Pricing Operations CONVATEC Operational Transfer Pricing Jean-Louis Barsac Having the right transfer pricing model is only half the story. Ensuring the policy is and has been implemented correctly is often the Head of Tax Moderator: 09:20 more significant challenge to overcome. The effective tax rate is usually dependant on the outcomes of the transfer pricing policy being implemented across the business, but this is usually a process that the tax team cannot control – but is a key stakeholder. VALEO Andrea Tolley Data and technology are seen as the key to fixing OTP, but is technology the answer? This session will discuss some of the common Partner, Head of OTP issues, how to identify them and more importantly where to start to address them. Transfer Pricing Corporates KPMG

10:00 Networking - Lounge Break or 1:2:1 Video Meetings

Andrea Lee John Thurstans Executive Assistant to Senior Manager, CFO/CRO International Tax PANEL DISCUSSION ERSTE GROUP VODAFONE Intragroup Financial Transactions Enrique Guzman Yordan Nenkov Both recent OECD guidance and a number of tax cases have focussed on the transfer pricing of intra-group financial transactions. In Transfer Pricing Head of Investment Tax 10:15 this session we will cover this topic in some detail including: • Discussion of the recent UK financial transactions TP case Manager PARTNERS GROUP • A review of global case law in relation to financial transactions TP HITACHI EUROPE • The interaction of the recent OECD FTT and COVID guidelines • Benchmarking financial transactions over periods of economic turbulence Moderator: Chris Liu Managing Director FTI CONSULTING

11:00 Networking - Lounge Break or 1:2:1 Video Meetings

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 13 PRESENTATION

How to Use Economic Modelling in Discussions on Transfer Pricing with Tax Authorities and in Tax Litigation Rutger Hafkencheid The OECD Transfer Pricing Guidance on Financial Transactions that was published last year explicitly mentions “economic Counsel; Tax Layer modelling” as a method that may be applied “in situations where reliable comparable uncontrolled transactions cannot be identified”. LOYENS & LOEFF Thus far, this surprising guidance has caught remarkably little attention. Unjustified, according to Rutger Hafkenscheid and Stephan 11:15 Kraan, the speakers at this plenary session. The speakers have experienced that economic modelling can provide very convincing support of a transfer pricing position in discussions with tax authorities and pivotal evidence in litigation cases, ranging from Stephan Kraan discussions about arm’s length debt level of group financing to “options realistically available” in business restructurings. Economic Senior Associate; Tax modelling may even mean the end of the benchmark as we know it today. It therefore opens a window of opportunities for improving Advisor the robustness of a transfer pricing system. In this interactive plenary session, Rutger Hafkenscheid and Stephan Kraan, members of LOYENS & LOEFF Loyens & Loeff’s Transfer Pricing and Economics Team, will demonstrate how economic models can be used in a modern transfer pricing practice and will share experiences they have gained over the past years with the use of economic modelling.

11:55 Networking - Lounge Break or 1:2:1 Video Meetings

Lucia Fedina Martin Lagarden PANEL DISCUSSION Director, Transfer Head of Global Transfer Intangibles Valuation, Benchmarking and ALP – Where Are we Now? Pricing Pricing As the OECD 2017 guidelines get ever more translated in national tax law and reflected in local tax audit practices, a rise of disputes CBRE HENKEL questions the sustainability of traditional IP valuation and benchmarking approaches. The panel will share practical experiences and 12:10 observed trends. From this, approaches to safeguard established solutions and new approaches to reward intangible contributions Moderator: Önder Albayrak will be discussed, including: Yves Hervé Head of Transfer Pricing • A changing tax audit landscape on intangible matters; Managing Director for Strategy & • DEMPE contributions and Intangible transfer pricing; • DEMPE contributions and cross-border transfer of intangibles; and NERA ECONOMIC Operations - Head of • Solving related tax disputes in practice CONSULTING Tax Benelux at Sanofi SANOFI

12:50 Networking - Lounge Break or 1:2:1 Video Meetings

Kurt Wulfekuhler Catherine Harlow PANEL DISCUSSION Director, Transfer Head of Transfer Pricing Managing TP and Defending Your TP Position Pricing ASTRAZENECA VERIZON There surely cannot have been a more challenging time to manage tax controversy over the last tumultuous year. And, as the world 13:05 economy slowly emerges from the economic and societal impacts of COVID-19, governments are already turning their attention Moderator: to how they will close the enormous fiscal gaps that have emerged in government budgets. Our august panel will be sharing their Paul Sutton Anton Hume recent experiences of the developing focus, nature and conduct of TP audits and the management of international controversy, and Co-Founder Tax Partner, Corporate their views as to how the environment in relation to TP controversy is likely to change over the coming years. LCN LEGAL International Tax BDO

13:45 Networking - Lounge Break or 1:2:1 Video Meetings

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 14 Elena Blanque Antoine Faure US Exec. V.P. of Finance Partner and Global Head of Tax DLA PIPER PANEL DISCUSSION GRUPO ANTOLIN APAs, MAP, ICAP and Managing TP Disputes Matteo Crispi Miguel Navas Head of Global Already a trend in recent years, global exposure to transfer pricing is expected to continue escalating in a post-Covid context where 14:00 States will look for additional taxable revenues to finance the exceptional measures implemented. Advance pricing agreements are a VP of Tax International Tax and way for multinational enterprises to achieve certainty and avoid transfer pricing exposure. CABIFY Transfer Pricing During this panel discussion, TP experts working in-house and in law-firms will share their experience and provide insights on how to BARILLA strategically address APA procedures for multinational companies. Moderator: Cesar Salagaray Partner DLA PIPER

14:40 Networking - Lounge Break or 1:2:1 Video Meetings

14:55 Chair’s Closing Remarks STREAM E STREAM F STREAM G STREAM H PANEL DISCUSSION PANEL DISCUSSION PANEL DISCUSSION PANEL DISCUSSION TP & the U.S. Tax Landscape Latest Developments in Brazil & Other The Rise of Transfer Pricing & Latest Latest TP Developments in Africa Latin America Markets International Tax Developments in the In a panel of transfer pricing experts for the Latin Middle East Joel Wilpitz Gareth Harrison American region, Bernardo Solano, Partner at Director of Global Transfer Pricing BaseFirma, will be discussing the most important Head of Tax SAZERAC COMPANY regulatory developments and trends around Mohamed Fayçal Charfeddine AIRTEL AFRICA transfer pricing audit activity. This will include Group Head of Tax Ainsley Gaddis the adoption of the OECD Model in Brazil and its AUJAN COCA-COLA Jere Tormanen Transfer Pricing Controversy Leader impact on intangibles. Head of Tax GE HEALTHCARE Vanessa Toro Hany Elnaggar BATA BRANDS VP Global Transfer Pricing Head of Tax for Middle East; JIACC Jared Walls UNILEVER Tax Commission Member Marike Rabie Partner NISSAN Head of Transfer Pricing 15:00 VALENTIAM GROUP Guilherme Alves STEINHOFF INTERNATIONAL South America Tax Manager Seema Sharma LOUIS VUITTON Head of Tax Vineet Rachh NETWORK INTERNATIONAL PLC Associate Director – Taxes Cintli Chacon PROCTOR & GAMBLE Global Head of Transfer Pricing Mary O’ Leary PUMA ENERGY Tax Lawyer | Tax Technology Lead at Moderator: Vizor | Tax & Digitalisation Dr Joshua Bamfo Monica Calijuri VIZOR Partner & Head, Economist - Sector Lead Specialist, Transfer Pricing Group Tax Administration Moderator: ANDERSEN NIGERIA IADB Rachit Agarwal Transfer Pricing Director Moderator: DLA PIPER Bernardo Solano Senior Partner BASEFIRMA

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 15 15:45 Networking - Lounge Break or 1:2:1 Video Meetings

PANEL DISCUSSION John C. Hughes Dominic Vines Director, APMA Team Leader (Financial TP); Delegated Understanding Tax Administrations’ Position on Current TP INTERNAL REVENUE SERVICE, U.S. Competent Authority Developments HMRC Norzilah Mat Arbak As in past years the panel for this session will consist of senior tax officials Bo Darling Larsen from various jurisdictions with a wide range of international tax experience. Deputy Director of Services Audit Division 16:00 As well as covering issues and questions arising from the topics indicated INLAND REVENUE BOARD MALAYSIA Head of Competent Authority below they will also seek to address themes and concerns that arise over the DANISH COMPETENT AUTHORITY course of the conference: Israel Ajayi • Preparations for the implementation of the final outcome of Pillars 1 & 2 Lead, International Tax &Transfer Pricing Moderator: • Approach to COVID policy adjustments including within APAs Audit (Oil & Gas Division) Martin Brooks • Resourcing given the need to raise revenue following COVID and the likely NIGERIA FEDERAL INLAND REVENUE Senior Adviser increases in tax disputes in the coming years SERVICE FTI CONSULTING

PRESENTATION 17:00 Live Q&A with the Tax Authorities

17:30 Chair’s Closing Remarks

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 16 POST-CONFERENCE WORKSHOPS Thursday, 17 June 2021 Workshop A (09:00 - 10:30) Workshop B (11:00 - 12:30) Workshop C (13:30 - 15:00) Workshop D (15:30 - 17:00) Practical Considerations Managing Complex Making TP Analyses for Operational Transfer for Financial Transfer Pricing Intangibles Tangible Pricing and Tax Function Transactions in Transfer Disputes and Transformation Overview: Pricing Controversy In this workshop, the team of Tiberghien Overview: team will share frameworks and practical In this workshop, RSM team will share their Overview: Overview: cases for addressing all transfer pricing experiences about the nature and importance In February 2020, the OECD released the final Transfer pricing disputes and controversy aspects in relation to intangibles (in the post- of operational transfer pricing, covering the document on transfer pricing and financial are no longer limited to international tax BEPS era) - from the basics, including a.o. challenges and practical aspects associated transactions. During this interactive session audits, MAP and APAs. Increasingly, they how to practically execute a DEMPE-analysis with identifying your intercompany transactions. we will explore some of the key points raised are occurring during financial audits, due – to the more advanced, including a.o. how to They will highlight leading practices associated with appropriate application of a transfer in the guidance and explore its practical diligence, state aid cases and situations overcome HTVI* valuation issues (*Hard-but- not-impossible-To-Value-Intangibles). pricing set up for intercompany transactions implications. The session will cover: involving minority shareholders. Many and ongoing monitoring of the transfer • Practical considerations when evaluating involve transactions that go beyond simple pricing practices, with examples on true-up implicit support; management fees or buy-sell distribution Andy Neuteleers adjustments and considerations. At the end of arrangements. Join us in this workshop, as this workshop, participants will be able to: • Case study on loan pricing and Partner Transfer Pricing Belgium we provide our latest insights on what types considerations; and & Luxembourg • Grasp the working mechanisms of OTP of complex transfer pricing disputes and TIBERGHIEN ECONOMICS • Align inter-company pricing policies with • Considerations when evaluating guarantee controversy we are seeing and how best transfer pricing processes and controls transactions to practically manage those involving your Heleen Van Baelen through OTP company. Senior Manager, Transfer Pricing • Understand automation as an impetus to draw TIBERGHIEN ECONOMICS input and align various corporate stakeholders Amanda Pletz via OTP Associate Director Brad Rolph Canada National Practice Leader; Kenny Van Tulder • Implement a reliable narrative for compliance NERA ECONOMIC purposes that covers both policies and data Transfer Pricing Senior Manager TP & Valuations CONSULTING under OTP GRANT THORNTON TIBERGHIEN ECONOMICS Bernardo Danesi Anju Singh Consultant Christoph Ludwig Tine Slaedts National Leader - Operational NERA ECONOMIC Partner; Tax - Transfer Pricing Partner, Transfer Pricing Transfer Pricing CONSULTING WARTH & KLEIN GRANT TIBERGHIEN ECONOMICS THORNTON RSM US Duncan Nott Transfer Pricing Partner RSM

Juan Dosal Blanco Transfer Pricing Practice Leader, Netherlands RSM

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 17 SUPPORTERS OF TP MINDS INTERNATIONAL 2021

LEAD PARTNER We are an independent expert-led tax practice, with definitive expertise across many areas of tax and a commercial approach to advising our clients. We provide tax advisory services which are client centric and focused on mitigating tax risk and minimising cost, and are the exclusive UK member of the WTS Global Network. Our transfer pricing team provides the full range of transfer pricing services from the development of pragmatic policies, efficient documentation and benchmarking solutions through to advising on the effective implementation and ongoing monitoring of those policies and their defence in the face of tax authority challenge. We have over 100 years of Big Four and ex-HMRC transfer pricing experience and draw on the unparalleled experience of over 120 economists who price complex commercial and financial transactions, undertake valuations of intangibles and stand as expert witnesses in litigation cases. As we are free from audit and assurance client relationships, our clients can be certain that we will always be in a position to defend their transfer pricing policies and advise them on an ongoing basis. www.fticonsulting.com CO PARTNER KPMG LLP, a UK limited liability partnership, operates from 21 offices across the UK with approximately 16,000 partners and staff. The UK firm recorded a revenue of £2.3 billion in the year ended 30 September 2020. KPMG is a global organization of independent firms providing Audit, Legal, Tax and Advisory services. It operates in 147 countries and territories and has more than 219,000 people working in member firms around the world. Each KPMG firm is a legally distinct and separate entity and describes itself as such. KPMG International Limited is a private English company limited by guarantee. KPMG International Limited and its related entities do not provide services to clients. www..co.uk GOLD PARTNERS

BDO’s award-winning national UK Transfer Pricing team of experts has expertise in tax, law, economics and finance. The team bring experience from a range of settings including professional services, industry and revenue authorities around the world. This strength and diversity of knowledge delivers fresh thinking and robust transfer pricing solutions.We work closely with our fellow transfer pricing experts in more than 50 countries across the BDO Global network. Our advice and insight helps develop and implement effective transfer pricing policies. We support our clients with economic analysis, evaluation of value chains, documentation strategies, advance pricing agreements and transfer pricing risk assessments as well as efficient dispute resolution. www.bdo.com/services/tax/transfer-pricing/overview SILVER PARTNERS A world leading provider of audit, tax and consulting services to entrepreneurial growth-focused organisations and multinationals globally. As an integrated team, we share skills, insight and resources, as well as a client-centric approach that’s based on a deep understanding of your business. Our global transfer pricing experts work together with you to understand your business and your requirements. This is The Power of Being Understood. • We are the 7th largest global audit, tax and consulting network • We have firms in over 110 countries • We have combined staff of over 37,500 in over 730 offices across the Americas, Europe, MENA, Africa and Asia Pacific www.rsmuk.com

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 18 Accenture is a global professional services company with leading capabilities in digital, cloud and security. Combining unmatched experience and specialized skills across more than 40 industries, we offer Strategy and Consulting, Interactive, Technology and Operations services—all powered by the world’s largest network of Advanced Technology and Intelligent Operations centers. Our 537,000 people deliver on the promise of technology and human ingenuity every day, serving clients in more than 120 countries. We embrace the power of change to create value and shared success for our clients, people, shareholders, partners and communities. www.accenture.com

Today, transfer pricing is one of the main tax issues faced by groups. Whether your business is a high-growth start-up or an established multinational, you need to comply with transfer pricing rules. This means that you need to have transfer pricing documentation available based on which tax authorities can assess how conditions were determined and whether they reflect market circumstances. The focus on transfer pricing has sharpened due to current developments within the OECD, the European Union and local jurisdictions. We see increasing numbers of countries implementing stringent transfer pricing documentation requirements. At the same time, businesses show concern with tax authorities vigilantly enforcing these new requirements in their quest for a larger share of the profits. With our integrated tax & legal expertise and comprehensive transfer pricing knowledge we advise businesses in our main service areas Documentation, Planning & Strategy and Dispute Resolution. www.loyensloeff.com/en/en

DLA Piper is a global law firm with lawyers located in more than 40 countries throughout the Americas, Europe, the Middle East, Africa and Asia Pacific, positioning us to help clients with their legal needs around the world. We strive to be the leading global business law firm by delivering quality and value to our clients. We achieve this through practical and innovative legal solutions that help our clients succeed. We deliver consistent services across our platform of practices and sectors in all matters we undertake. Our clients range from multinational, Global 1000, and Fortune 500 enterprises to emerging companies developing industry-leading technologies. They include more than half of the Fortune 250 and nearly half of the FTSE 350 or their subsidiaries. We also advise governments and public sector bodies. dlapiper.com

NERA has developed one of the largest in-house teams of economists in the economic consulting world. Our Global Transfer Pricing Practice offers a full range of transfer pricing services, independent advice, and valuation support by worldclass economists who operate in major locations around the globe and who team effectively to provide global solutions for multinational clients. Our direct, hands-on approach to transfer pricing enables us to develop more rigorous, higher quality products, and to collaborate more effectively with our clients. Because we are a firm of unbiased economic practitioners, many of the leading law firms from around the world have also engaged us to create valuable and sustainable solutions for their multinational corporate clients and as experts in litigation and arbitration. Our team of experts has substantial senior-level experience, and we work collaboratively with multinational clients and their legal and tax advisors to provide the highest level of practical hands-on advice and support, applying sophisticated economics-based techniques when necessary to tackle more difficult issues. Clients range from some of the largest and best known companies in the world to midsize companies, and they cover numerous iconic brands. www.nera.com/practice-areas/transfer-pricing.html

At S&P Global Market Intelligence, we know that not all information is important—some of it is vital. We integrate financial and industry data, research and news into tools that help track performance, generate alpha, identify investment ideas, understand competitive and industry dynamics, perform valuation, and assess credit risk. Investment professionals, government agencies, corporations, and universities globally can gain the intelligence essential to making business and financial decisions with conviction. S&P Global Market Intelligence is a division of S&P Global (NYSE: SPGI), which provides essential intelligence for individuals, companies, and governments to make decisions with confidence. www.spglobal.com/marketintelligence/en

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 19 Bureau van Dijk combines data from regulatory and other sources, including over 160 information providers, to deliver the richest, most reliable private company information, corporate structures, beneficial ownership and deal information in the market. Orbis, our leading company and entity database, has detailed and comparable information on more than 41 million companies globally, and close to 400 million in total. This information is combined with our intuitive and powerful software to deliver the best solution for arm’s-length analysis available. A key benefit of our information is how simple we make it to compare companies internationally. As experts in company information, we can help you to monitor your global operations and comply with country by country (CbyC) reporting. Equip yourself for these challenges with TP Catalyst, a tool that simplifies the process of identifying comparables and produces the required analyses for transfer pricing reporting. Welcome to the business of certainty. Request your free trial using the link below. www.bvdinfo.com/en-gb/solutions-for-your-role/transfer-pricing

At BaseFirma, we are a team of economists, international tax lawyers, accountants, and financial . With over 650 clients in 30 countries on four continents, BaseFirma has a strong physical presence in all major markets. Our services range from providing transfer pricing documentation, country-specific reports, and audit defense, to tax structuring, implementation of transfer pricing models, and valuation of intangible assets. All services we provide are aligned with local regulations and with recent global initiatives of BEPS environment , such as, the new OECD Transfer Pricing Documentation, Master File, Local File and country by country reports. BaseFirma, the most dominant US transfer pricing firm in Latin America, continues to expand its activities in South America. Our new Sao Paulo office just opened at the JK complex, the distinguished landmark at Vila Olímpia. After 16 years of consecutive growth in the Americas, BaseFirma has strengthened its position as the industry leader in Latin America. wwww.basefirma.com

Tiberghien economics is a consultancy boutique of senior economists, capable of dealing with any transfer pricing matter and (tax) valuation challenge. Tiberghien economics also offers tailor-made expert support in the fields of business modeling and innovation tax regimes. Tiberghien and Tiberghien economics have entered into a network agreement that serves as a joint platform to address the challenges of our mutual clients with a multidisciplinary mindset, and with global reach, both being a member of WTS Global for Belgium and Luxembourg. www.tiberghieneconomics.com ASSOCIATE PARTNERS LCN Legal is an international consultancy which specialises in helping multinational groups to create and maintain the Intercompany Agreements and legal structures they need for transfer pricing compliance. We are the authors of the book “Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide”. We don’t advise on tax, transfer pricing, benchmarking or economic analysis – so we are truly independent and we support rather than disrupt your existing relationships. Our team supports multinational groups and their transfer pricing advisers around the world, and we are passionate about bridging the gap between tax and legal, and helping our clients to create international structures with genuine legal substance. www.lcnlegal.com

To register or for the latest information, please visit: https://informaconnect.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 20 With Taxtimbre we believe it is time for an independent to bridge the gap between Business, Tax and Finance. Our tax team is built up of tax and transfer pricing professionals with extensive in-house and Big Four experience. Taxtimbre taps, through Finext into a network with in-depth technology knowhow of more than 150 skilled and certified Enterprise Performance Management professionals. Finext have been implementing the most leading performance management solutions at a large variety of international companies for almost 20 years. Our transfer pricing team understands the drivers and architecture of business models and how this translate to transfer pricing. For us it is not about ‘one-tool- one trick”, but about solving a specific content or process problem with technology where it makes sense: from design, all the way through to configuration and implementation. We make use of the software and systems already available in the company, or where required we help with selecting, and implementing, what is available in the market. Our commitment is to reduce the workload of people, improve regulatory reporting compliance, as well as improve the robustness of companies’ business models. We also believe in incremental change, a company does not have to approach automation as a large scale technological project, but can start with incremental changes and improvements. www.taxtimbre.com

Ectacon is a modern, hands-on and fully independent transfer pricing consultancy. Ectacon, founded in 2015, connects tax and economics. Based in Amsterdam, Ectacon combines specialist knowledge and broad experience with a practical and pragmatic approach. Ectacon’s goal is to support clients with a carefully considered strategy in transfer pricing and related international tax and economic matters. Ectacon is fully independent and regularly works with transfer pricing specialists, tax advisors and economic experts worldwide. Ectacon provides expertise on both a regular consulting basis and on a collaborative sourcing (co-sourcing) basis. ectacon.com/en/team/gerben-weistra

Vizor Software is a global technology provider trusted by financial regulators and tax authorities across the globe. Operating in over 19 jurisdictions, Vizor specializes in cross-border information exchange solutions for tax authorities, helping them to reduce tax evasion and tax avoidance. With more than 20 years of industry experience and proven delivery methodology, Vizor has been consistently selected through competitive public procurement by tax authorities such as the Bahamas Ministry of Finance, HM Government of Gibraltar, Nigeria Federal Inland Revenue Service, and Ministry of Finance UAE, to facilitate CbC Reporting, CRS, FATCA and ETR exchanges. www.vizorsoftware.com

Duff & Phelps’ team of internationally recognized transfer pricing advisors provide the technical expertise and industry experience necessary to ensure understandable, implementable and supportable results. Fulfilling complex transfer pricing requirements can be a daunting task for any multi-national organization. As experts in transfer pricing, Duff & Phelps provides an independent and uncompromised perspective on all aspects including compliance, planning, controversy and implementation. Our Services Include • Cost sharing arrangements • Global tax efficient supply chain strategies • Global and country-specific transfer pricing documentation • OECD policy analysis • Multi-State transfer pricing analysis • Acquisition integration assistance to align potentially disparate transfer pricing systems www.duffandphelps.com/services/valuation/transfer-pricing

RoyaltyStat® offers proprietary databases of royalty rates and global company financials. We include interactive transfer pricing analytics. RoyaltyStat’s online databases are searchable to find comparable agreements and companies (enterprises) to determine arm’s-length royalty rates and OECD specified profit indicators, including the gross profit margin, Berry ratio, operating profit markup, and return on operating assets. RoyaltyStat’s interactive software tools enable subscribers to calculate statistical (such as interquartile) data ranges, make assets adjustments, and perform regression analyses to determine reliable royalty rates and profit indicators to benchmark inter-group transactions. www.royaltystat.com

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 21 At Grant Thornton, transfer pricing is more than a tax compliance exercise – it’s a unique opportunity to drive business value and foster growth. As a critical tax obligation for all multinational companies, the transfer pricing group at Grant Thornton specializes in planning, implementing, documenting and defending transfer pricing positions to actually drive business value. We support organizations in all areas of transfer pricing—from complex planning, to navigating documentation frameworks, to defending transfer pricing positions at the field, appeals, and competent authority levels. The Grant Thornton transfer pricing group is unique in the marketplace, offering a full scope of services balanced by a highly personal and customized approach. With 35 practitioners including six partners and principals, our transfer pricing practice in Canada is one of the largest in the country. www.grantthornton.com MEDIA PARTNER IFC Media is the leading publishing house for the global wealth management industry. Representing international finance centres across the globe while creating a comprehensive archive of commentary, analysis and technical articles, IFC Media publications include the flagship IFC Review annual, the annual IFC Economic Report and regional reviews such as the Caribbean Review. Supplementing our hard copy publications is ifcreview.com, which houses the monthly IFC Review E-Journal and the IFC Review digital library and archive. Created as an online resource for wealth management professionals, ifcreview.com combines reference materials with highly technical articles and thought-provoking commentary from industry leading contributors. With continually updated coverage from over 30 international finance centres and daily news bulletins, ifcreview.com is a one-stop-shop for wealth management professionals right across the globe. IFC Media delivers an integrated knowledge base for the world’s leading IFCs and their wealth management professionals. www.ifcreview.com

To register or for the latest information, please visit: https://finance.knect365.com/tp-minds-international-conference/ Tel: +44 (0) 20 7017 7790 Email: [email protected] 22