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WCO/OECD Conference on Transfer Pricing and Customs Valuation

Customs and related party transactions: Is it desirable / possible

to converge Customs Valuation and Transfer Pricing?

Brussels (Belgium), 03 and 04 May 2006

Day 1

Day 2

Wednesday 3 May, 2006
9:30	Welcome by WCO and OECD - Michel Danet, Secretary General, WCO - Richard Hecklinger, Deputy Secretary-General, OECD
Session 1	Transfer Pricing Methods Globalisation and importance of multinational enterprises in economic development What is transfer pricing and how does it work for multinational enterprises? Recent trend regarding transfer pricing Why is transfer pricing important: implications for multinational enterprises, for tax authorities and for customs administrations? Economic and development implications of transfer pricing OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations National Tax responses to transfer pricing Do developing countries need Transfer Pricing Regulations? Moderator : Franz Tomazek,General Manager:Legislation,South African Revenue Service
10:00	Introduction and overview by the Moderator
10:20	Presenter 1: Chriticles Mwansa, Director, Tariff and Trade Affairs Directorate, WCO
10:40	Presenter 2: Mexico Tax Administration
11:00	Presenter 3: Berlin Msiska, Commissioner General, Zambia Revenue Authority
11:20	Refreshment Break
11:50	Presenter 4: Guglielmo Maisto,Professor of Tax Law,University of Piacenza,Italy
12:10	Open discussion
13:00	Lunch Break
Session 2	Customs Valuation of Related Party Transactions Determination of customs value under the WTO Valuation Agreement, National customs response to related party transactions, Desirability of developing guidelines concerning the customs response to related party transactions, Capacity building in developing countries in respect of the customs valuation of related party transactions. Moderator : Aziz El Kassimy, Deputy Director, Tariff and Trade Affairs Directorate, WCO
14:30	Introduction and overview by the Moderator
14:50	Presenter 1: Eki Kim, Economic Affairs Officer, Market Access Division, WTO
15:10	Presenter 2: Canada Customs administration
15:30	Presenter 3: Belgium Customs administration
15:50	Presenter 4: business / industry / academic:Deloitte Europe
16:10	Refreshment Break
16:40	Open discussion
18:00	Close of Day 1

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Thursday 04 May 2006
Session 3	Bridging the gap (part 1): comparison of custom valuation and transfer pricing methods (principles and outcomes) Definition of “related parties” and “associated enterprises” Methods: traditional methods, profit methods, arm’s lengthrange, hierarchy of methods, choice of the method by the taxpayer Services and intangibles Aggregation of transactions Practical experience of comparability and relevance of functional and economic analysis Moderator : Marlies de Ruiter,Deputy Director, Directorate for International Tax Policy and Legislation, Ministry of Finance, the Netherlands
9:30	Introduction and overview by the Moderator
10:00	Presenter 1: LIU Ping, Senior Technical Officer, Tariff and Trade Affairs Directorate, WCO
10:20	Presenter 2: Caroline Silberztein, Head, Transfer Pricing Unit, Centre for Tax Policy and Administration, OECD
10:40	Presenter 3: business/ industry academic: Martin Jovanovich, Baker McKenzie, Buenos Aires
11:00	Open discussion: In what circumstances could OECD Transfer Pricing methods (including profit methods) be used for customs valuation rules? In what circumstances could customs valuation influence transfer pricing?
11:30	Refreshment Break
12:00	Bridging the gap (part 2): desirability and feasibility of having converging standards Presenter: Vanda Davis, Director of Tax-Australia, Ford Motor Company of Australia Limited
12:20	Open Discussion: Pros and cons from the perspective of customs, from the perspective of transfer pricing and from the operational perspective of business To what extent is it acceptable to have different rules because the policy objectives are different? Do different answers to the same question “what is the arm’s length price” alter the credibility of the assessing authorities? If converging standards are found desirable,would the 1995 Transfer Pricing Guidelines form a suitable basis?
13:00	Lunch Break
Session 3	Bridging the gap (part 3): desirability and feasibility of coordinated administrative approaches Scope for joint advanced customs and transfer pricing agreements Exchange of information between customs and tax authorities Confidentiality provisions Scope for joint audit: customs and transfer pricing audit practices, consequences of a transfer pricing adjustment on previously accepted customs value and vice versa, consequences of a customs authority statement that the value of the transaction cannot be used because the relationship influenced the price on the income tax area Moderator : Kunio Mikuriya, Deputy Secretary General, WCO
14:30	Introduction and overview by the Moderator
14:50	Presenter 1: Martine Milliet-Einbinder, Head, Unit of International Cooperation and Exchange of Information, OECD
15:10	Presenter 2: Ian Cremer,Valuation Policy Advisor,Frontiers,HM Revenue and Customs, UK
15:30	Presenter 3: Antoine Glaize,Avocat Associé, Thérèse-Anne Amy, Avocat, Directeur Douane, Ernst & Young société d’avocats, Paris
15:50	Presenter 4: Mark Ludwig,Partner, Worldtrade Management Services, PricewaterhouseCoopers
16:10	Refreshment Break
16:40	Open discussion
17:40	Wrap-up session
18:00	Close of Symposium

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