strategic tax & finance week: transfer pricing & tax ... · strategic tax & finance...

20
C LARIDEN Singapore | Sydney | Melbourne | Dubai | Hong Kong | London | New York | San Francisco | Toronto | Auckland STRATEGIC TAX & FINANCE WEEK: TRANSFER PRICING & TAX STRUCTURE OPTIMISATION CLARIDEN GLOBAL TAX INSITUTE CLARIDEN CREDENTIALS AND ENGAGEMENT Clariden Global is the pre-eminent and influential global business leadership institution. Today, we host more than 200 global executive education and major conference events around the world. We have partnered with professional organizations such as the Association of Chartered Certified Accounts (ACCA) and thought leaders from prestigious universities such as Harvard University John F. Kennedy School of Government, Wharton School of the University of Pennsylvania and Stanford University. Balancing Multiple Tax Jurisdictions Rules and Achieving Optimum Tax Structures PROGRAM B: OPTIMISING TAX STRUCTURES WITH INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT 24 - 25 May 2017 Hilton London Bankside PROGRAM A: TAX EFFICIENT TRANSFER PRICING AND INTRA-GROUP FINANCING 22 - 23 May 2017 UNITED KINGDOM

Upload: others

Post on 01-Jun-2020

10 views

Category:

Documents


0 download

TRANSCRIPT

C L A R I D E N Singapore | Sydney | Melbourne | Dubai | Hong Kong | London | New York | San Francisco | Toronto | Auckland

STRATEGIC TAX & FINANCE WEEK: TRANSFER PRICING & TAX STRUCTURE OPTIMISATION

CLARIDEN GLOBAL TAX INSITUTE

CLARIDEN CREDENTIALS AND ENGAGEMENTClariden Global is the pre-eminent and influential global business leadership institution. Today, we host more than 200 global executive education and major conference events around the world. We have partnered with professional organizations such as the Association of Chartered Certified Accounts (ACCA) and thought leaders from prestigious universities such as Harvard University John F. Kennedy School of Government, Wharton School of the University of Pennsylvania and Stanford University.

Balancing Multiple Tax Jurisdictions Rules and Achieving Optimum Tax Structures

PROGRAM B:OPTIMISING TAX STRUCTURES WITH INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT24 - 25 May 2017

Hilton London Bankside

PROGRAM A:TAX EFFICIENT TRANSFER PRICING AND INTRA-GROUP FINANCING22 - 23 May 2017

UNITED KINGDOM

The Clariden Experience

Why Clariden Global Executive Education?

Optimising Tax Structures With International Tax Planning, Compliance and Risk Management5 Program Introduction7 Faculty Director8 Program Overview9 Program Outline

Concurrent Program: Tax Efficient Transfer Pricing and Intra-Group Financing10 Program Introduction12 Faculty Directors14 Program Overview15 Program Outline

Participating Companies

Testimonials

In-house Custom Executive Programs

Contact Us

Registration

3

4

5

10

16

17

18

19

CONTENTS

20

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected]

THE CLARIDEN EXPERIENCEENJOY LEARNING WITH THE

FIRST-CLASS, WELL-ROUNDED EXPERIENCE

3

To maximize both your enjoyment and professional development, Clariden Global holds its executive programs at five star hotels, some of which include:

Shangri-La Hotel, SingaporeSingapore

Conrad London St JamesLondon, United Kingdom

InterContinental Melbourne The RialtoMelbourne, Australia

Grand Hyatt: Union Square San Francisco HotelSan Francisco, United States

Amidst lush gardens, this 3-wing luxury hotel is 6 km from the iconic Marina Bay Sands resort and 9 km from Sentosa. 

Across the street from St. James’s Park tube station, this sophisticated hotel is 10 minutes’ walk from Buckingham Palace and 2 miles from the Victoria and Albert Museum. 

Set in a grand 1891 building, this upscale chain hotel is 3 blocks from the Yarra River, and an 8-minute walk from the SEA LIFE Melbourne Aquarium. 

Less than a block from Union Square, this stylish high-rise hotel is an 11-minute walk from the Moscone Center and 1.9 miles from Pier 39.

Terms & Conditions: Clariden Global International Limited reserves the right to change the venue of the program due to reasons beyond their control.

WHY CLARIDEN GLOBAL EXECUTIVE EDUCATION?

5,000+Companies

15+Countries

10,000+Participants

50+Industries

GLOBAL ENGAGEMENT Clariden Global is the pre-eminent and influential global business leadership institution. Today, we host more than 200 Global Executive Education and major conference events across 15 countries and 17 cities, including Singapore, London, Hong Kong, Sydney, Melbourne, Perth, New Zealand, San Francisco, Toronto, Johannesburg, Shanghai, Beijing, Kuala Lumpur, Dubai, Toronto, The Netherlands, New York and Zurich.

INTERNATIONALLY DIVERSE, SENIOR-LEVEL PARTICIPANTSClariden Global Executive Education programs have attracted participants from more than 5,000 global MNCs, regional corporations, and FORTUNE 500 companies, from more than 40 countries. All applications are reviewed based on professional achievement and organizational responsibility. Designed for individuals at all levels, from top executives to emerging leaders, each intensive program is crafted to equip leaders with essential capabilities to improve corporate performance and position their organizations to thrive.

THOUGHT LEADERSHIPTo provide strategic insights and relevant world-class executive education to global organizations, Clariden Global engages the best thought leaders and leading authorities from around the world. These include professors and faculty leaders from Harvard University, Stanford University, University of Pennsylvania Wharton, London Business School and other premium institutions to deliver transformational knowledge.

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 4

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 5

PROGRAM ESSENCE

In continuance from programme A, this programme is designed to help tax professionals and head of businesses develop the most optimal financing structure that can maximise their organisation’s bottom line while fully complying with legal guidelines. Former tax advisor of OEDC, Carine Stoffels, will guide you to identify core considerations in tax planning and how to handle them with tax-efficient solutions.

Through this in-depth training programme, tax professionals will be able to gain latest insights on BEPS, international, regional, and domestic tax developments. Carine will prompt you to rethink and explore how different tax considerations, such as residence, permanent establishments, and transfer pricing, can help organisations achieve tax-effectiveness. At the same time, Carine will shed light on how to ensure transparency and compliance with country-by-country reporting, tax rulings, and mandatory disclosure rules.

PROGRAM BOPTIMIZING TAX STRUCTURES WITH

INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT

DATES24 - 25 May 2017

LOCATIONHilton London Bankside

TUITION FEESEarly Bird 1 (Register & pay by 27 March 2017): £1,795Early Bird 2 (Register & pay by 24 April 2017): £1,895Regular Tuition Fees: £1,995

For limited time only by 24 April 2017, register 3 participants and the 4th participant will receive a complimentary seat (one discount scheme will apply).

PROGRAM ADVISORKaren WoodsEmail: [email protected]: +44 (0) 20 7129 1222

PROGRAM INFORMATION

FACULTY DIRECTOR

• Expert consultant for IMF, London School of Economics, and other private clients on tax law, policy and compliance issues

• Former tax advisor for OECD, advising OECD member countries, G20 non-member countries and other non-member countries on tax law, policy and compliance matters, including the implications of the OECD/G20’s Base Erosion and Profit Shifting (BEPS) Project

• UK and Belgian qualified tax lawyer with 17 years of international tax experience both in private practice and in the international tax policy arena

• Speaker and training facilitator at various international tax conferences and seminars

Carine Stoffels

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 6

• Understand international, regional, and domestic tax developments (OECD & BEPS guidelines) that can affect business (re)structuring, compliance and risk management

• Discover and evaluate core considerations such as residence, permanent establishment, transfer pricing, tax incentives, beneficial ownership, and more

• Explore core considerations such as tax rulings, mandatory disclosure rules, country-by-country reporting, to ensure tax transparency to ensure compliance

• Learn to utilise offshore holding/financing/IP for better international tax planning• Understand implications of supply chain structures and how to better implement (re)structuring supply chain

structures with transparency and compliance

This program is designed for but not limited to tax specialists, finance and accounting professionals, trade and customs professionals, supply chain and logistics experts who are seeking to learn or increase their experience in international tax, indirect tax and transfer pricing concepts, as well as MD / GM / CEO and Head of businesses who are considering restructuring their businesses.

KEY BENEFITS

WHO WILL ATTEND THIS PROGRAM

PROGRAM BOPTIMISING TAX STRUCTURES WITH

INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT

In addition, you will learn to utilise offshore holding, financing, and IP in your tax planning strategies to ensure tax-effectiveness with full compliance. Last but not least, you will have the chance to discover the implementation of supply chain (re)structuring to improve tax efficiency. Through case studies and intense group discussion, Carine will stretch your thoughts constructively and guide you to realign your tax practices and acquire better financial performance with an optimal tax structure.

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 7

International Tax Expert

Carine Stoffels is a trusted international tax expert, advising IMF, London School of Economics Enterprise, and other private clients on tax law, policy and compliance issues. She started off her career as a tax lawyer for almost nine years, working, first, in Belgium, then in the UK before moving on to her former role in OECD.

Prior to becoming an independent tax consultant, Carine was Advisor within the International Co-operation and Tax Administration Division of the OECD’s Centre for Tax Policy and Administration, where she was heavily involved in the OECD’s work on aggressive tax planning and exchange of information. Carine led a series of regional and country-specific OECD workshops, seminars and other training and capacity building events for tax administrations in OECD and non-OECD member countries.

With 17 years of consulting experience with respectable financial institution such as OECD and IMF in the field of tax management, Carine has garnered years of expertise in aggressive tax planning and tax compliance. She has been a frequent speaker and facilitator at various workshops, seminars, and conferences around the world.

Carine completed the International Tax Program at Harvard Law School, Advanced Specialised Studies in International and European Law and an Advanced Degree in Tax Law at the University of Brussels. She was admitted to the roll of solicitors in England and Wales in October 2009 and was a member of the Brussels Bar as a Belgian qualified lawyer from October 2000 to June 2010.

FACULTY DIRECTOR

Carine Stoffels

PROGRAM BOPTIMISING TAX STRUCTURES WITH

INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 8

The ever-changing complex tax system poses as one of the significant issues to businesses today. If tax planning is done in a poor manner, businesses might see their bottom line bleeding through unintended tax risks such as higher tax payment, poor treasury management, non-compliance, and unforeseen disputes. In order to thrive in today’s hyper-competitive market, you and your organisation need to have an in-depth understanding of the current tax systems in order to maximise tax-saving while avoiding legal risks.

Following programme A, this course will complete your understanding on crucial aspects of tax planning to ensure tax-efficiency. Former tax advisor of OEDC, Carine Stoffels, will assist you to improve tax structuring practice and handle business issues with tax-efficient solutions.

With case studies and interactive discussions throughout the two-day course, tax professionals will have the chance to rethink and witness how different tax considerations can help organisations achieve tax-effectiveness. Tools and considerations, such as residence, transfer pricing, beneficial ownership, and permanent establishment, along with offshore holding, financing, IP that are key to achieving tax-efficiency will be covered. You will also learn to ensure tax compliance within transfer pricing guidelines, tax ruling, and mandatory disclosure rules. Insights on BEPS and OECD guidelines will also be shared to help you maintain compliance and avoid risks and disputes. In addition, you will be given the ins and outs of tax efficient supply chain management to improve your organisation’s tax efficiency.

By the end of this course, you will be equipped with knowledge on tax regulations, ability to identify and analyse your organisation’s tax and business issues, and to make decisions that allow more tax-savings.

OVERVIEW

PROGRAM OVERVIEWOPTIMISING TAX STRUCTURES WITH

INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT

This course has been independently certified as conforming to accepted CPD guidelines. On average, this executive program contributes 16 hours towards your CPD. Delegates must register at the start and close of each workshop to be awarded a certificate of completion.

CPD CERTIFICATION DETAILS

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 9

PROGRAM OVERVIEWOPTIMISING TAX STRUCTURES WITH

INTERNATIONAL TAX PLANNING, COMPLIANCE AND RISK MANAGEMENT

DAY 1Session 1: Setting the scene • Key drivers and steps to tax-effective business (re)structuring• General overview of international (OECD/G20, EU and other) and domestic tax developments affecting business

(re)structuring, compliance and risk management

Session 2: Key corporate tax considerations in the post-BEPS tax landscape – Substance• Residence • Permanent establishments• Transfer pricing • Beneficial ownership • Tax incentives (including patent boxes)• Anti-avoidance rules (treaties, EU, domestic)

Session 3: Key corporate tax considerations in the post-BEPS landscape – Transparency• BEPS: transfer pricing (country-by-country reporting), tax rulings, mandatory disclosure rules• Other developments in the area of transparency and exchange of information (on request and automatic)

DAY 2Session 4: Use of Holding/Financing/IP Companies post-BEPS • Common holding/financing/IP structures• Use of offshore holding/financing/IP companies• Key operational, tax and transparency considerations in (re)structuring holding/financing/IP activities

Session 5: Tax efficient supply chain management post-BEPS• Examples of supply chain structures• Key operational, tax and transparency considerations in (re)structuring supply chain structures

Sessions 6 - 7: Group case study and conclusions

09:00 - 17:00 / 24 May 2017

09:00 - 17:00 / 25 May 2017

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 10

FACULTY DIRECTORS

• Expert consultant for IMF, London School of Economics, and other private clients on tax law, policy and compliance issues

• Former tax advisor for OECD, advising OECD member countries, G20 non-member countries and other non-member countries on tax law, policy and compliance matters, including the implications of the OECD/G20’s Base Erosion and Profit Shifting (BEPS) Project

• UK and Belgian qualified tax lawyer with 17 years of international tax experience both in private practice and in the international tax policy arena

• Speaker and training facilitator at various international tax conferences and seminars

• Transfer pricing expert, providing technical assistance to developing countries on behalf of the UN and World Bank

• Member of the UN Sub-Committee Group in charge of the Draft of the Practical Manual on Transfer Pricing for Developing Countries

• Former transfer pricing advisor for OECD. Participated in the work of WO6 regarding the revision of Chapter I-III of the OECD TP Guidelines and the inclusion of the new Chapter IX on the transfer pricing aspects of business restructurings

• Author of various articles in transfer pricing journals and publications

Carine Stoffels

Giammarco Cottani

DATES22 - 23 May 2017

LOCATIONHilton London Bankside

TUITION FEESEarly Bird 1 (Register & pay by 27 March 2017): £1,795Early Bird 2 (Register & pay by 24 April 2017): £1,895Regular Tuition Fees: £1,995

For limited time only by 24 April 2017, register 3 participants and the 4th participant will receive a complimentary seat (one discount scheme will apply).

PROGRAM ADVISORKaren WoodsEmail: [email protected]: +44 (0) 20 7129 1222

PROGRAM INFORMATION

YOU MAY BE INTERESTED INPROGRAM A

TAX EFFICIENT TRANSFER PRICING AND INTRA-GROUP FINANCING

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 11

• Stay on top of current transfer pricing and intra-group financing developments in the region

• Discover the application of transfer pricing to common business models• Explore measures to achieve tax-effectiveness with value chain optimisation• Understand different types of intra-group financing activities• Discover transfer pricing considerations, such as hybrid mismatch arrangements, controlled foreign company,

interest deductibility, to build better transfer pricing strategies

• Learn to apply BEPS guidelines to financing models and ensure tax compliance

This program is designed for but not limited to tax specialists, finance and accounting professionals, trade and customs professionals, supply chain and logistics experts who are seeking to learn or increase their experience with international tax, indirect tax and transfer pricing concepts, as well as MD / GM / CEO and Head of businesses who are considering restructuring their businesses.

KEY BENEFITS

WHO WILL ATTEND THIS PROGRAM

PROGRAM ATAX EFFICIENT TRANSFER PRICING

AND INTRA-GROUP FINANCING

PROGRAM ESSENCE

Since Apple’s unprecedented $14 billion tax penalty by the European Commission in August, tax authorities worldwide, especially in Europe, are now scrutinising international companies’ tax practices to examine their structures and compliance. In fact, EU Commissioner has warned that this is only the beginning for international firms. To help you achieve full tax compliance and efficiency in your tax planning, Clariden is pleased to invite you to our two-day Tax Efficient Transfer Pricing and Intra-Group Financing programme this May.

Led by a former advising international tax expert for OECD and IMF—Carine Stoffels and her partner, tax advisor to the World Bank, OECD, and UN – Giammarco Cottani, this comprehensive programme will show you as tax leaders how to develop your intra-group financing and transfer pricing strategy to ensure your organisation’s tax structure is efficient and at the same time, tax compliant with financial and tax legislations, and in local statutory requirements, which are dynamic in nature. Carine and Giammarco will walk you through the latest developments and issues of transfer pricing, as well as authorities’ perspective on the matters. You will have the chance to explore how to carry out transfer pricing methods with different business models to improve your business efficiency.

In addition, Carine and Giammarco will shed light on measures of value chain optimisation, in order to maximise tax benefits with a cost-effective value chain framework. You will also gain insights on the latest developments of BEPS and explore considerations such as hybrid mismatch arrangement, controlled foreign company, interest deductibility, and many more, to help you ensure tax compliance and minimise / avoid tax disputes.

Through case studies and interactive discussion, Carine and Giammarco will challenge you intellectually and stretch your thoughts constructively throughout the programme. She will guide you to make sense of current transfer pricing principles and better control transfer pricing practice, so you can guard your profit against unnecessary loss.

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 12

International Tax Expert

Carine Stoffels is a trusted international tax expert, advising IMF, London School of Economics Enterprise, and other private clients on tax law, policy and compliance issues. She started off her career as a tax lawyer for almost nine years, working, first, in Belgium, then in the UK before moving on to her former role in OECD.

Prior to becoming an independent tax consultant, Carine was Advisor within the International Co-operation and Tax Administration Division of the OECD’s Centre for Tax Policy and Administration, where she was heavily involved in the OECD’s work on aggressive tax planning and exchange of information. Carine led a series of regional and country-specific OECD workshops, seminars and other training and capacity building events for tax administrations in OECD and non-OECD member countries.

With 17 years of consulting experience with respectable financial institution such as OECD and IMF in the field of tax management, Carine has garnered years of expertise in aggressive tax planning and tax compliance. She has been a frequent speaker and facilitator at various workshops, seminars, and conferences around the world.

Carine completed the International Tax Program at Harvard Law School, Advanced Specialised Studies in International and European Law and an Advanced Degree in Tax Law at the University of Brussels. She was admitted to the roll of solicitors in England and Wales in October 2009 and was a member of the Brussels Bar as a Belgian qualified lawyer from October 2000 to June 2010.

FACULTY DIRECTOR

PROGRAM ATAX EFFICIENT TRANSFER PRICING

AND INTRA-GROUP FINANCING

Carine Stoffels

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 13

Head of Transfer PricingLudovici Piccone & Partners

Giammarco Cottani is partner and head of transfer pricing practice at Ludovici Piccone & Partners, a leading Italian tax law firm. He currently serves as a Member of the Sub-Committee Group of the United Nations in charge of the Draft of the Practical Manual on Transfer Pricing for Developing Countries, and he is also the Delegate for Italy on a number of OECD Working Parties.

Until August 2015, Giammarco acted as Advisor on International Tax to the Central Assessment Director of Italy Revenue Agency. He was one of the delegates for Italy involved in the OECD BEPS project. Prior to joining the Agency, he worked as a Transfer Pricing Advisor in the Tax Treaty and Transfer Pricing Unit of the OECD, where he was involved in the introduction of the new Chapter IX of the OECD Transfer Pricing Guidelines concerning business restructurings.

With experience around the globe with reputable organisations, Giammarco possess deep understanding in the field of transfer pricing. He is a member of the faculty of the International Tax Center, the University of Leiden for transfer pricing. He regularly lectures in postgraduate courses in international taxation, with a specific focus on transfer pricing, both in Europe and the United States. Giammarco is currently providing technical assistance for a number of tax administrations projects in several LATAM countries on behalf of World Bank and UN.

FACULTY DIRECTOR

PROGRAM ATAX EFFICIENT TRANSFER PRICING

AND INTRA-GROUP FINANCING

Giammarco Cottani

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 14

With transfer pricing row hanging over corporate giants like Apple and Facebook in 2016, transfer pricing continues to be a main priority for multi-national corporations. As penalties for found cases of transfer pricing have extended not only to financial terms, but also in terms of reputation damage and extra scrutiny from tax authorities, businesses are taking extra measures to help themselves navigate through the complex sea of international tax legislations and guidelines.

Understand your need for better transfer pricing insights, this comprehensive two-day programme will help tax professionals improve your intra-group financing practices and protect your organisations’ bottom line. Led by an international tax expert for OECD and IMF, Carine Stoffels, and her partner, tax advisor to World bank, OECD, and UN – Giammarco Cottani, this programme will show you how to develop intra-group financing strategies to achieve tax-effectiveness with different business models.

This comprehensive programme will shed light on issues surrounding transfer pricing and tax regulation developments around them. Carine and Giammarco will show you how to align your intra-group financing plan with your organisation’s supply chain framework. Our facilitators will walk you through the steps of value chain optimisation to achieve tax-effectiveness. You will also have the chance to look at transfer pricing from tax authorities’ perspective and learn how different financing aspects, such as hybrid mismatch arrangements, controlled foreign company, and interest deductibility, affect your intra-group financing strategy.

Through case studies and interactive discussion, Carine and Giammarco will challenge intellectually and stretch your thoughts constructively throughout the programme. By the end of the course, you will be able to make sense of current transfer pricing guidelines, better control transfer pricing practice, and guard your profit against unnecessary loss.

OVERVIEW

PROGRAM OVERVIEWTAX EFFICIENT TRANSFER PRICING

AND INTRA-GROUP FINANCING

This course has been independently certified as conforming to accepted CPD guidelines. On average, this executive programme contributes 16 hours towards your CPD. Delegates must register at the start and close of each workshop to be awarded a certificate of completion.

CPD CERTIFICATION DETAILS

DAY 1 – TRANSFER PRICINGSession 1: Setting the scene• Transfer pricing in general and transfer pricing of intra-group financing specifically: an area of growing scrutiny

and controversy• Tax authorities’ focus on transfer pricing further advanced by the OECD’s BEPS Project and other developments,

including through country-by-country reporting • Impact of those developments on business (re)structuring, compliance and risk management strategies

Session 2: Transfer pricing and supply chain management• Common business models – Key concepts – Business restructurings of manufacturing and distribution functions

– Intellectual property management• The application of transfer pricing methods to post-restructuring scenarios – The notion of control over risk and

financial capacity to assume the risk

Session 3: The management of supply chain in the new BEPS landscape • Value chain analysis: concept; tax-effectiveness and the role of CCAs• Value Chain and Intercompany services • The new transfer pricing landscape post-BEPS (BEPS Actions 8-10; 13)• Value chain optimisation and proper transfer pricing documentation

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 15

09:00 - 17:00 / 22 May 2017

PROGRAM OUTLINETAX EFFICIENT TRANSFER PRICING

AND INTRA-GROUP FINANCING

DAY 2 – INTRA-GROUP FINANCING: TRANSFER PRICING AND NON-TRANSFER PRICING ASPECTSSession 4: Importance and types of intra-group financing

Session 5: Impact of BEPS and other developments on intra-group financing• Transfer pricing aspects of intra-group financing (BEPS Actions 8-10; 13)• Non-transfer pricing related aspects of intra-group financing: hybrid mismatch arrangements (BEPS Action

2), controlled foreign company (CFC) rules (BEPS Action 3), interest deductibility (BEPS Action 4), harmful tax practices work (BEPS Action 5), Preventing tax treaty abuse (BEPS Action 6)

Sessions 6 - 7: Case study and conclusions regarding sustainable transfer pricing policies and finance models

09:00 - 17:00 / 23 May 2017

PARTICIPATING COMPANIESMore than 5,000 companies have participated in our programs

ADVERTISING, INTERNET, MEDIA, PUBLISHINGBBC WorldwideCNNeBayLinkedInMediaCorpSaatchi & SaatchiSingapore Press HoldingsThe Financial Times The Hoffman AgencyThe Walt Disney CompanyThomson Reuters

CONGLOMERATEFraser & NeaveGeneral ElectricGeneral MotorsMitsubishi MonsantoSiemens AGSodexo

FINANCIAL SERVICES, INSURANCEBank of America Merrill Lynch AIAAllianz Global InvestorsAmerican ExpressAvivaAXABarclays BankCitibankDBS BankDeutsche BankHSBCJP Morgan Chase BankManulifeMasterCardMaybankMizuho BankOCBC BankPayPalPrudentialRabobankStandard Chartered BankSuncorpSwiss ReinsuranceTD SecuritiesVisaWestpacZurich Insurance

FOOD, BEVERAGECoca-Cola BeveragesDanoneFerreroHeinekenMcDonaldPepsiCo

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 16

GOVERNMENT, NONPROFITAustralian Securities and Investments CommissionCentral Provident Fund BoardChangi Airport GroupEconomic Development BoardGICNSW TreasurySercoTemasek Group

HEALTHCARE, PHARMACEUTICALSAbbott LaboratoriesEu Yan SangGlaxosmithklineHoffmann-La RocheJohnson & JohnsonMerckPfizerSanofi

HOSPITALITYCapitaLandFar East OrganizationFrasers HospitalityHilton WorldwideMarriott HotelsPan Pacific Hotels GroupShangri-La Hotels & Resorts

MANUFACTURING (CONSUMER)British American Tobacco Estee LauderFonterra BrandsHeinekenKimberly-ClarkKraft FoodsLegoMars Foods NestléProcter & Gamble Unilever

MANUFACTURING (INDUSTRIAL)AirbusCorning Optical CommunicationsDaimler Harley DavidsonIntel SemiconductorRolls-RoyceVolvo GroupWearnes Automotive

OIL & GAS, NATURAL RESOURCESCaltexChevronConocoPhillipsExxonMobilMaersk

PetronasSantosSaudi Arabian OilSchlumbergerShell

PROFESSIONAL SERVICESAECOMAon HewittErnst & YoungPricewaterhouseCoopers

RETAIL, TRADEAdidasCargillDFSHarvey NormanHennes & MauritzIKEAL’OrealMarks and Spencer NTUC FairpriceTesco

TECHNOLOGY, ELECTRONICS3MAppleCanonDellHewlett PackardIntel TechnologyLenovoMicron TechnologyMicrosoftOracleSAPSony ElectronicsTE Connectivity

TELECOMMUNICATIONSEricssonNokiaOlive Communications SingtelStarhubTata CommunicationsTelstraVerizonVodafone TRANSPORTATIONAuckland TransportCathay Pacific AirwaysDubai Air Navigation ServicesNew Zealand Transport AgencyFiji AirwaysMetro Trains MelbourneNSW TrainsSBS Transit

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 17

FACULTY DIRECTORCARINE STOFFELS’

TESTIMONIALS

This was an excellent session. Very informative and a very knowledgeablepresenter. Really good and would like to see what other courses are available.

“We work with many advisors that provide great advice in their specialist area. It’s rare to find an advisor that can take a broad perspective across technical areas and combine this knowledge to establish a practical business friendly solution.”

US MNC – Chemical Industry

Commercial and Finance OfficerTDSi2

“ ““

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 18

PROGRAM ADVISORKaren WoodsEmail: [email protected]: +44 (0) 20 7129 1222

Carine Stoffels is a trusted international tax expert, advising IMF, London School of Economics Enterprise, and other private clients on tax law, policy and compliance issues.

With 17 years of consulting experience with respectable financial institution such as OECD and IMF in the field of tax management, Carine has garnered years of expertise in aggressive tax planning and tax compliance. She has been a frequent speakers and facilitators at various workshops, seminars, and conferences around the world.

CONTACT US

IN-HOUSECUSTOM

EXECUTIVEPROGRAMS

Clariden Global delivers custom learning programs for organizations all around the world. Whatever your business challenges are, we create focused learning experience that enables your organization to achieve success. Through partnerships with the most renowned thought leaders, industry experts and professors from around the world, these in-house custom executive programs will equip you with essential skills and capabilities to develop and implement strategies more effectively at your organization.

Engage with our thought leader today:

International Tax ExpertCarine Stoffels

Contact Karen Woods, Program Director at +44 (0) 20 7129 1222 | [email protected] 19

CONTACT US

We encourage you to learn more about Clariden Global Executive Education custom and open-enrollment programs. Our staff will be happy to answer your questions and help you determine the programs work best for you and your organization.

ENQUIRY FOR THIS PROGRAMKaren WoodsEmail: [email protected]: +44 (0) 20 7129 1222

SINGAPOREEmail: [email protected]: +65 6899 5030Fax: +65 6567 4328Address: Clariden Global Pte Ltd  3 International Business Park #04-29, Nordic European Centre Singapore 609927

LONDONEmail: [email protected]: +44 (0) 20 7129 1222Fax: +44 (0) 84 3218 0413Address: 1 King Street London, EC2V 8AU United Kingdom

AUSTRALIAEmail: [email protected]: +61 3 9909 7310Fax: +61 3 9909 7788Address: Clariden Global Pty Ltd 530 Little Collins Street, Level 1 Melbourne VIC 3000, Australia

CUSTOMIZED PROGRAMSKaren WoodsEmail: [email protected]: +44 (0) 20 7129 1222

REGISTRATION & PAYMENT MATTERSEmail: [email protected]: +44 (0) 20 7129 1222

REGISTRATION

Program B (24 - 25 May 2017) Optimising Tax Structures With International Tax

Planning, Compliance and Risk Management £1,795 £1,895 £1,995

Program A (22 - 23 May 2017) Tax Efficient Transfer Pricing and

Intra-Group Financing £1,795 £1,895 £1,995

PROGRAM FEES

C L A R I D E N

Program1st Early Bird Fee

(If payment & registrations are received

by 27 Mar 2017)

2nd Early Bird Fee(If payment &

registrations are received by 24 Apr 2017)

Regular Fee Per Participant

Email: [email protected]

Fax: +44 (0) 84 3218 0413

Call: +44 (0) 20 7129 1222

Website: www.claridenglobal.com

By Cheque/ Bank Draft

By Telegraphic Transfer

By Credit Card

Group discount of 10% for the 2nd participant from the same organization. For limited time only by 24 April 2017 register 3 participants and the 4th participant will receive a complimentary seat.*One discount scheme applies.

An invoice and registration confirmation will be sent within 7 days, please contact us if you have not heard from us within 7 days. Payment details will be sent together with the invoice based on your preferred payment method.

ALL PAYMENTS MUST BE RECEIVED IN ADVANCE OF THE EVENT.

FEE RECEIVED REFERENCE L7107.08/VL/KC

4 WAYS TO REGISTER 3 PAYMENT METHODS

GROUP DISCOUNTS

FOR OFFICIAL USE

Booking Contact (Approving Manager) Mr/Mrs/Ms:___________________Job Title:____________________ Department:____________________Telephone:_______________________ Fax:_______________________Email:______________________________________________________Organization:_______________________________________________Address:________________________________________________________________________________________Postal Code:____________

I would like to receive more information on hotel accommodation using Clariden Global coporate rate.

Please register the following participant for this seminar.(Please tick to select your seminar(s). You may tick more than one.)

1st Participant Name (Mr/Mrs/Ms):_________________________________Job Title:___________________ Department:__________________________Telephone:_________________________ Fax:_________________________Email:_________________________________ Date of Birth:_____________

2nd Participant Name (Mr/Mrs/Ms):_________________________________Job Title:___________________ Department:__________________________Telephone:_________________________ Fax:_________________________Email:_________________________________ Date of Birth:_____________

3rd Participant Name (Mr/Mrs/Ms):_________________________________Job Title:___________________ Department:__________________________Telephone:_________________________ Fax:_________________________Email:_________________________________ Date of Birth:_____________

4th Participant Name (Mr/Mrs/Ms):_________________________________Job Title:___________________ Department:__________________________Telephone:_________________________ Fax:_________________________Email:_________________________________ Date of Birth:_____________

Seminar(s): Program A Program B□ □

Seminar(s): Program A Program B□ □

Seminar(s): Program A Program B□ □

Seminar(s): Program A Program B□ □

Hilton London Bankside

22 - 25 May 2017

2-8 Great Suffolk St, London SE1 0UG, UK

+44 20 3667 5600

http://www3.hilton.com/en/hotels/united-kingdom/hilton-london-bankside-

Accommodation is not included in the program fee but you will be entitled to use our corporate rate for your accommodation. Information will be sent along with your registration confirmation.

Once we have received your booking, the place(s) are confirmed. No refunds will be made for any cancellations, however, program credits of equivalent value only applicable for Clariden Global events will be provided. Credits can only be redeemed for 1 program and is valid for only one (1) year from date of issue.

Substitution with a qualified candidate is allowed by providing at least 5 working days of advance notice to Clariden Global. One time substitution is allowed with no charges. Subsequent substitutions will be charged 10% admin fee.

PLEASE NOTE: Clariden Global International Limited reserves the right to change the content and timing of the programme, the speakers and the date and venue due to reasons beyond their control. If in the unlikely event that the course is cancelled, Clariden Global International Limited will refund the full amount and disclaim any further liability.

PRIVATE DISCLOSURE STATEMENT: Any information provided by you in relation to this event is being collected by Clariden Global International Limited and will be held in the strictest confidence. It will be added to our database for the primary purpose of providing you with information about future events and services.

VENUE AND ACCOMMODATION INFORMATION

CANCELLATIONS AND SUBSTITUTIONS*All cancellations must be received in written form.