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2nd Joint WCO/OECD Conference on Transfer Pricing and Customs Valuation

Transfer Pricing, Indirect Taxes and VAT :

Exploring Possible Convergences

Brussels (Belgium), 22 and 23 May 2007

Day 1

Day 2

Day 1 : Tuesday 22 May 2007
08.30	Registration
09.15	Welcome by WCO and OECD WCO : Michel Danet, Secretary General, WCO OECD : Thelma Askey, Deputy Secretary General, OECD Introduction outcome of the 1st Conference and objective of the 2nd Conference Chriticles Mwansa, Director, Tariff and Trade Affairs, WCO
Session 1 09:45 - 11:05	Transfer pricing, Customs and VAT: Where do they meet? How different/similar are the valuation rules for transfer pricing, Customs and VAT? Definition, scope, principles and outcomes Methods: Transaction value and alternate methods (Customs), open market value (VAT), traditional transaction methods and transactional profit methods (transfer pricing), arm's length range, hierarchy of methods, aggregation of transactions and year-end adjustments Valuation treatment of specific costs and charges, services and intangibles Documentation requirements Moderator: Kunio Mikuriya, Deputy Secretary General, WCO
09.55	Ian Evans, Global Leader - Tax services, Grant Thornton International
10.15	Caroline Silberztein, Centre for Tax Policy and Administration, OECD Liu Ping, Tariff and Trade Affairs Directorate, WCO
10.55	TAXUD, European Commission
11.05	Networking break
Session 2 11:35 - 13:00	Regional overview and recent developments on convergence and coordinated approaches Regional and national status and developments: What are the issues? What are the initiatives adopted or underway? What investments are Customs and tax authorities making regarding the interaction between direct and indirect taxation rules, including institutional structure, administrative power and tools and training of Customs/tax officials? How is the business community working with the realities and corporate structures to comply with existing divergent rules? What business strategies MNEs are adopting to proactively integrate and manage the transfer pricing Customs valuation nexus? Where do they see the direction going? Moderator: Thelma Askey, Deputy Secretary General, OECD
11.45	Bill Methenitis, Americas Director--Customs and International Trade, Ernst & Young, LLP Franck Berger, Head of transfer pricing practice, Ernst & Young,France
12.05	Luc Dupont, Senior Program Advisor, Valuation Program Unit, Canada Border Services Agency
12.25	Ernest Sigande, Assistant Commissioner, Customs and Excise, Zambia Revenue Authority
12.45	Questions and answers
13.00 - 14:30	Lunch and networking time
Session 3 14:30 - 16:10	Exploring convergence: (1) The debate continues ... Desirability and feasibility of converging standards and coordinated administrative approaches from the operational perspective of business The two “schools of thoughts” and recommendations for possible ways forward as emerged from the 1st joint WCO-OECD Conference: - To what extent is it acceptable to maintain different rules because the policy objectives, legal frameworks and enforcement rules are different? - To what extent is it desirable to overcome the divergences and/or to encourage coordinated administrative approaches (e.g. in terms of lower compliance and enforcement costs)? If both sets of rules were to converge, what should be the common basis? Is there room for developing customs valuation guidelines based on the OECD Transfer Pricing Guidelines? Is there any contribution that customs valuation rules could make to the current or future review of the OECD Transfer Pricing Guidelines? How should regional variations be taken into account in identifying needs and means for possible convergence and coordinated administrative approaches?
14.30	Eki Kim, Counsellor, Market Access Division, WTO
14.50	Darrel Pearson, Partner, Gottlieb & Pearson
15.10	Juan Martin Jovanovich, JMP Law
15:30	Richard Thompson Ainsworth, Director (International) Government Affairs, ADPTaxware
15.50	Questions and answers
16.10	Networking break
Session 3 16:40 - 18:00	Exploring convergence: (2) Case study: Transfer pricing methods: traditional transaction methods and transactional profit methods, year-end adjustments
16.40	Panel discussion Lorrie Rodbart, Attorney-Advisor, U.S. Customs and Border Protection, Department of Homeland Security Mark Ludwig, Partner, World Trade Management Services, PricewaterhouseCoopers Montserrat Trapé, Partner, Tax, Global Transfer Pricing Services, KPMG, Spain
17.40	Questions and answers
18.00	Cocktail
18.30	Close of Day 1

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Day 2 : Wednesday 23 May 2007
Session 4 09:00 - 11:00	Specific issues : (1) Valuing intangibles Theoretical framework Definitions and scope; how divergent the rules are Significance of intangibles in the commercial world and current business models in relation to the development and exploitation of intangibles Valuation approaches for transfer pricing, Customs and VAT purpose Moderator: Carmine Rotondaro, Group Tax and Real Estate Director, GUCCI Group N.V.
09.20	Caroline Silberztein, Centre for Tax Policy and Administration, OECD
09.40	Isabel Verlinden, Partner, Transfer Pricing Eurofirm leader, Pricewaterhouse Coopers Ruud Tusveld, Partner, Customs & International Trade, Pricewaterhouse Coopers
10.20	John Malone, TAXUD, European Commission
10.40	Questions and answers
11.00	Networking break
Session 4 11:30 - 13:00	Specific issues: (2) Case study: Valuation of intangibles (transfer pricing, Customs and VAT) Moderator: Carmine Rotondaro, Group Tax and Real Estate Director, GUCCI Group N.V.
11.40	Shanto Ghosh, Director and Principal Economist, Deloitte, Haskins and Sells, Mumbai
12.00	Todd Smith, Senior Manager, International Corporate Services, West Region Leader, Trade and Customs Services, KPMG LLP
12.20	Stefaan De Baets, First Attaché of Finance, Chair of the Knowledge Group on Transfer Pricing, Cabinet of the Administrator General of Taxes and Recovery Federal Public Service Finance, Belgium
12.40	Questions and answers
13.00	Lunch and networking time
Session 5 14:30 - 16:40	Specific issues: (3) Administrative cooperation for better dispute prevention Can APAs (Advanced Pricing Agreements) work for Customs? What is an APA? Under what circumstances can an APA for transfer pricing purposes be acceptable for indirect tax purposes? Scope for joint APAs on customs and transfer pricing Practical experience relating to the comparability and relevance of functional and economic analysis Moderator: Shri Dutt Majumder, Chief Commissioner of Customs, Mumbai
14.50	Monique Van Herksen, Partner, Baker & McKenzie, Netherlands Jean-Philippe Lacroix, Customs Corporate Manager, PSA Peugeot Citroën
15.20	Matthew Bannon, Director, Valuation & Origin, Australian Customs Services Christopher Thomas, Director, Transfer Pricing Practice, Australian Tax Office
15.50	Damon Pike, President, the Pike Law Firm Steven Wrappe, Partner, Mayer Brown Rowe & Maw LLP
16.00	Questions and answers
16.30	Networking break
Session 6 17:00 - 18:00	Specific issues: (4) Exchanges of information, international dispute resolution mechanisms: can more be done for customs?
17.10	Panel discussion Jeffrey Owens, Director, Centre of Tax Policy and Administration, OECD Pascal Saint-Amans, Head of Litigation Department, Direction Générale des Impôts, France
17:30	Wrap-up session Outcome of the conference: What does the future hold for Transfer Pricing, Customs and VAT?
17.40	Kunio Mikuriya, Deputy Secretary General, WCO Jeffrey Owens, Director, Centre of Tax Policy and Administration, OECD
18.00	Close of Conference

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