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Transfer Pricing 2014

Highlights Include:

  • Keynote Address by Srini Lalapet, Associate Director, Transfer Pricing, Americas Region, AIG on AIG’s Best Practices in Managing Their In-House Transfer Pricing Function
  • Overview of OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS)
  • Latest Update on OECD’s Revised Draft on Intangibles
  • Ramifications of Parliamentary Investigations on Transfer Pricing • Summary of the Latest Significant Tax Court Cases Not to Be Missed by In-House Practitioners
  • Open Forum Panel Discussions on Transfer Pricing Planning, Implementation, Documentation, and Audit Management


In-House Transfer Pricing Practitioners
Managers, Directors, and VPs of:

  • Transfer Pricing
  • International Tax
  • Corporate Tax
  • Taxation
  • Finance
  • Taxation Advisers
  • Transfer Pricing Consultants
  • CFOs

Advisory and Law Firms
Managers, Partners, Principals of:

  • International Tax
  • Tax, Dispute Resolution, Tax Controversy
  • Transfer Pricing
  • Directors of Economics

Transfer Pricing Consultants, Experts, and Advisers

February 20, 2014

8:00 Registration and Continental Breakfast
8:30 Welcome Remarks from Insight Information

Welcome and Opening Remarks from the Chair

Matthew Wall, CA CBV
Transfer Pricing Expert
MDW Consulting Inc


Ramifications of Parliamentary Investigations on Transfer Pricing

Shiraj Keshvani
Partner, Global Transfer Pricing and Tax Controversy
Deloitte & Touche
former APA Coordinator/ Chief Economist, Canada Revenue Agency

  • Discussion on U.S. investigations of Microsoft and HP
  • Overview of U.K. investigations of Amazon, Google, and Starbucks
  • What this means for Canadian companies: issues and action steps

TG20 and G8 Focus on Base Erosion and Profit Shifting (BEPS)

Sean Kruger
Partner, Transfer Pricing and Supply Chain Planning
Ernst & Young

  • Summary of OECD’s Action Plan on Base Erosion and Profit Shifting
  • Discussion on the unanimous endorsement of OECD’s Action Plan in July 2013 by G20 Finance Ministers
  • Addressing 15 actions steps that will change tax and transfer pricing
  • How it is going to work and what it means for your company
10:45 Networking Coffee Break

Latest Update on OECD’s Revised Draft on Intangibles

Matthew Wall, CA CBV
Transfer Pricing Expert
MDW Consulting Inc.

  • Overview of August 2013 revisions on intangibles
  • Key changes in tax, valuations, and transfer pricing
  • What these revised changes mean internally for your company
12:00 Networking Luncheon

Update from the CRA: What You Need to Know

Tony Wark
Associate Partner, Transfer Pricing Services
Ernst & Young

  • What’s new at the CRA: audits, competent authority, and tax court appeals
  • Overview of CRA’s new risk-based audit approach
  • Discussion on tax authorities’ method of using CUPs for pricing transactions
  • Maintaining good relationship with tax authorities: CRA’s outlook

Update on Tax Court Cases: Important Lessons

Salvador M. Borraccia
Baker & McKenzie

  • Highlights from recent tax court cases in Canada, the US, and other countries
  • New concerns for certain related party structures and transactions
  • Implications and ramifications for Canadian companies
3:00 Networking Coffee Break

Overview of UN Transfer Pricing Manual: What It Means For Your Company

Dan McGeown
Canadian Transfer Pricing Leader
BDO Canada

  • What countries are now using UN Transfer Pricing Manual?
  • When to use the OECD Guidelines, UN Manual, or both?
  • Potential audit issues, disputes, and double taxation
  • What this means for Canadian companies

Approaching Transfer Pricing from a Risk Management Perspective

Chris Raybould
Director of Economics
Baker & McKenzie

  • Summary of April 2013’s OECD Draft Handbook on Transfer Pricing Risk Assessment
  • Risk assessments that are now being used by tax authorities to audit multinationals
  • Developing transfer pricing risk management framework for your company
  • Introduction of risk assessments for tax planning, documentation and audits
5:00 Conference Adjourns for the Day

February 21, 2014

8:00 Continental Breakfast

Opening Remarks from the Chair

Matthew Wall, CA CBV
Transfer Pricing Expert
MDW Consulting Inc


PANEL DISCUSSION: Best Practices in Transfer Pricing Planning and Implementation

Brad Rolph
National Transfer Pricing Leader
Grant Thornton Consulting

Kevin Locke
Senior Manager, Tax and Transfer Pricing
CHC Helicopter

Joy Nott
Canadian Importers and Exporters Association

  • Administration, organization, and implementation of transfer pricing: making it come alive
  • Getting started: educating senior-management and operations on the importance and value of your own in-house transfer pricing practice
  • How to get buy-in from the senior management to invest into internal resources
  • Project implementation: working together with HR, finance, treasury, accounting, etc.
  • Getting your methodology in place and deciding on the main source of justification that your company wants to use
  • Gathering local comparables when North-American comparables don’t work
  • Gathering information to make adjustments to prices
10:00 Networking Coffee Break

PANEL DISCUSSION: Traps, Tips, and Tricks: Keeping Up With Your Documentation Requirements

Greg Noble
Partner, Vancouver Tax Leader
Ernst & Young

Marie-Pierre Thivierge
Senior Consultant, Transfer Pricing
Rio Tinto

Kevin Locke
Senior Manager, Tax and Transfer Pricing
CHC Helicopter

Elona Drenova
Manager, Tax and Transfer Pricing
TD Bank

  • Overview of August 2013 OECD Whitepaper on Transfer Pricing Documentation
  • Practical tips for drafting your transfer pricing documentation and transactions
  • Managing local and global documentation from a consolidation vs. statutory perspectives
  • Best practices in preparing your documentation: real-life examples

PANEL DISCUSSION: Transfer Pricing Audits from A to Z: Developing Bulletproof Audit Defence Strategy

Agnes Mak
Partner, Tax, Global Transfer Pricing Services
KPMG Canada

Paul Lynch
National Leader, Tax Dispute Resolution and Controversy
KPMG Canada

Mark Novak
VP Taxation and Tax Counsel
Aviva Canada

Jeff Chiasson
VP, Finance
Soft-Moc Inc.

  • Managing various stakeholders – internal and external auditors
  • Time management: how much time to dedicate to audits in order to avoid playing catch-up later?
  • What are the steps in effectively managing tax audit activity?
  • Addressing the issue of inexperienced field auditors: disconnect between senior CRA members and field representatives
  • How to interact with tax authority during audits: what is acceptable and what is not acceptable?
  • Overview of best experiences and methodology that successful practitioners rely on when defending against tax authority
  • CRA’s perspective on successful audit management process
  • If push comes to shove and when to get help by teaming up with external resources
  • Maximizing the value of outside help by developing bulletproof audit defence strategy
12:30 Networking Lunch

KEYNOTE PRESENTATION: Managing the In-House Transfer Pricing Function – Practical Insights and Best Practices

Srini Lalapet
Associate Director, Transfer Pricing, Americas Region

AIG is a leading international insurance organization serving customers in more than 130 countries. AIG companies serve commercial, institutional, and individual customers through one of the most extensive worldwide property-casualty networks of any insurer. In addition, AIG companies are leading providers of life insurance and retirement services in the United States.

  • Managing the transfer pricing function in-house within a large multinational – challenges and opportunities
  • Transfer pricing risk identification and mitigation strategies
  • Transfer pricing process and project management – planning, documentation and audit defence – practical tips
  • Balancing coverage vs. efficiency and creating value – key insights for the in-house practitioner
  • Transfer pricing policy setting, transaction management and implementation – case study
  • Regional considerations – Americas, EMEA, and Asia-Pacific
2:30 Networking Coffee Break

Advice From Your Peers: Addressing In-House Transfer Pricing Challenges

Pierre Bocti
VP, Tax

Natalia Ples
Senior Corporate Taxation Adviser
Cirque du Soleil

Alina Flis-Wiacek
Senior Manager, Transfer Pricing
Tim Hortons

  • What are some of the common transfer pricing dilemmas that in-house professionals are facing these days across Canada?
  • How Canadian companies are implementing transfer pricing practices at their organizations: what worked and what didn’t
  • What discussion boards to follow and what resources to rely on when getting external help is out of the question?
  • Making the most out of available resources and getting the best results possible
  • Practical issues in day-to-day work, real-life examples, success stories, and best practices in solving industry challenges
4:00 Conference Concludes


(Includes meals, documentation and inCONFERENCE, fully searchable online access to this conference’s papers*)

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CLE Accreditation

This program has been approved by the Law Societies of Upper Canada and Saskatchewan CPD for 17 substantive hours.

The Barreau du Québec automatically recognizes training activities held outside the province of Quebec and accredited by another Law Society which has adopted MCLE for its members. This program is thus approved by the Barreau du Québec for 17 hours.

For Alberta lawyers, consider including this course as a CPD learning activity in your mandatory annual Continuing Professional Development Plan as required by the Law Society of Alberta.