TAX CERTAINTY DAY 16 September 2019 OECD Conference Centre, Paris,

Monday 16 September 2019 (CC9) 9:30 – 10:00 Item 1. Opening Session: Welcome and Introduction: Why does tax certainty matter? Welcome and introduction with reflections the importance of tax certainty for economic growth and cross-border investment, links to the work on taxing the digital economy and its significance from a tax administration perspective. • Eduard Müller, Federal Minister of Finance, Republic of Austria • Pascal Saint-Amans, Director, Centre for Tax Policy and Administration, OECD • Will Morris, Chair, BIAC Tax Committee 10:00 – 11:00 Item 2. Panel: Tax certainty and the bigger picture Release of the 2018 MAP Statistics and key messages from the data. Panel discussion on the state of tax certainty across different tools and dimensions and how to facilitate holistic and integrated processes. This would include looking at what is working, what needs improvement, what is missing and what could be added taking account of different cultural issues and organisational structures. • Chair: Achim Pross, of International Cooperation and Administration Division, OECD • Panellists:

o Ted Gallivan, Assistant Commissioner, Revenue Agency o Alan McLean, Executive Vice President Taxation, Shell Coffee break (11:00 – 11:30) 11:30 – 12:30 Item 3. Advance Pricing Agreements This panel will focus on routes to provide MNEs with early bilateral/multilateral legal certainty, focussing on APAs and Finland’s Cross-Border Dialogue initiative. The panel will discuss the experience of tax administrations and taxpayers, the main challenges faced and options for improving the process and timelines for agreeing APAs. • Chair: Alexandra MacLean, Director General International Business, Canada Revenue Agency • Panellists:

o Katherine Amos, Global Head of Transfer Pricing, Johnson&Johnson o Rocio Bermudez, Global Transfer Pricing Manager, REPSOL o John Hughes, Chair of FTA MAP Forum o Mark Johnson, Head of Unit, OECD o Kristina Juth, Senior Adviser, Tax Finland o Jere Törmänen, Head of Tax, Lunch break (12:30 – 13:30) 13:30 – 15:00 Item 4. MAP and arbitration This panel will cover learnings and areas for improvement deriving from an analysis of the MAP statistics, including steps recently taken by jurisdictions to improve dispute resolution. It will cover ways to reduce the MAP pipeline by an effective use of dispute prevention tools including ICAP, APAs, and joint audits. It will include a discussion around future developments for MAP and arbitration including the work on multilateral MAPs. • Chair: John Hughes, Chair of FTA MAP Forum • Panellists:

o Karsten Flüchter, Head of Division, MAPs and APAs, Federal Central Tax Office, o Sharon Katz-Pearlman, Head of Global Tax Dispute Resolution & Controversy Team, KPMG o Sandra Knaepen, Head of Unit, OECD o Erik Knijnenburg, Global Head of Tax & Transfer Pricing, H&M o Evelyn Lio, Assistant Commissioner, Inland Revenue Authority of o Martin O’Rourke, Competent Authority Transfer Pricing, HMRC, 15:00-15:30 Item 5. Co-operative compliance: The view from Austria (including questions and answers) • Eduard Müller, Federal Minister of Finance, Republic of Austria

Coffee break (15:30-16:00) - Group Photo 16:00-16:30 Item 6. Co-operative compliance: The view from France (including questions and answers) • Gérald Darmanin, Minister of Public Action and Accounts, France 16:30-17:30 Item 7. Panel – Co-operative compliance and ICAP This panel will focus on the role of co-operative compliance and the OECD ICAP pilot in promoting tax certainty. Panellists will discuss the tax administration and taxpayer experience of co-operative compliance regimes and how these continue to evolve. Panellists will also share experiences in the first ICAP Pilot and an update on ICAP 2.0, which launched in June 2019. • Chair: Jo Wakeman, Director Large Business Directorate, HMRC, United Kingdom • Panellists:

o Jennifer Best, Director Treaty and Transfer Pricing Operations Practice Area, Internal Revenue Service,

o Letizia Coviello, Group Tax Director, Prada o Mark Johnson, Head of Unit, OECD o Giuseppe Lamberti, Group International Tax Director, Prada o Ronald Russo, Professor, Fiscal Institute, Tilburg University o Graeme Wood, Director, Global Taxes – Transfer Pricing, Procter & Gamble o Marco Zonetti, Large Taxpayer Department, Italian Revenue Agency

17:30 – 18:30 Item 8. Joint Audit This panel will focus on joint audits, what they are and how they work, discussing both key benefits and challenges and exploring next steps in advancing this work. This will include possible pilots, special training sessions on case selection, conduct of a joint audit and other relevant aspects. • Moderator: Nadia Altenburg, OECD • Panellists:

o Jesper Barenfeld, Senior Vice President, Head of Tax, Volvo Group o Sven Bremer, Head of Group Transfer Pricing, Siemens o Eveline Klein Entink, Coordinator International Co-operation – Large Business Segment, Dutch Tax Administration

o Kirsten Rösel, Project Manager, International tax audits, Federal Central Tax Office, Germany 18:30 – 18:45 Item 9. Wrap up 18:45 Cocktail Reception (Room George Marshall)

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