Venue
Vienna University of Economics and Business
Vienna University of Economics and Business, Welthandelsplatz 1 1, 1020 Wien, Austria

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Event Date Mon Oct 29 HKT (about 3 years ago)
In your timezone (EST): Mon Oct 29 12:00am - Mon Oct 29 12:00am
Location Vienna University of Economics and Business
Welthandelsplatz 1 1, 1020 Wien, Austria
Region APAC
Details

The fundamental question of what constitutes an “intangible” has led to controversies in the transfer pricing
area. Further, evaluation of whether there has been an actual transfer of intangibles leads to the enquiry
of appropriate compensation for the transfer. A prolonged conflict arising from differences in treatment
of intangibles from accounting, legal and tax perspective has resulted in further conflicts. Traditionally
intangibles include patents, know-how, trademarks, franchise etc. However, evolution of transfer pricing rules
has led to debate on recognition of the relevance of other topics, such as Location Specific Advantages (LSA),
assembled workforce, group synergies. Issues surrounding marketing intangibles have also led to heightened
litigation. This session will provide an overview and analysis on the definition of intangibles along with the
support of a case study and recent judicial precedents on this topic.

Speakers

2018 Speakers:

Raffaele Petruzzi
Managing Director, WU Transfer Pricing Center, WU CEO, L&P Global, Member, UN Subcommittee on Transfer Pricing

Alfred Storck
Co-Chairman of the Board of Directors, WU Transfer Pricing Center, WU

Robert Risse
Corporate Vice President and Head of Finance Tax & Trade Group, Henke

Rakesh Bhaskar
Principal Commissioner, Income Tax Mumbai

Yves Boulmer
Head of Valuation, Central Tax Office for Large Enterprises/MAP-APA Office, The Norwegian Tax Administration

Jon Clark
Transfer Pricing Specialist, HMRC

Dr. Giammarco Cottani
Head of Transfer Pricing, Ludovici Piccone & Partners

Axel Eigelshoven
Partner, German Transfer Pricing Leader, PwC

Marlinda Gianfrate
Large Taxpayers Directorate - Advance Agreements and International Disputes Office,, Head of Rome branch, Italian Revenue Agency

Martin Lagarden
Head of Global Transfer Pricing, Henkel

Daniel Liebchen
Tax Advisor, Partner, Flick Gocke Schaumburg

Dr. Emmanuel Llinares
Senior Vice President, NERA Economic Consulting

Colin Miller
Transfer Pricing Specialist, Swedish Tax Agency

Martin Schwaiger
Head of Transfer Pricing Team, Ministry of Finance

Paul Simpson
Assistant Director, Business Assets & International – Shares and Assets, Valuation, HMRC

Julia Stoltenberg
Senior Tax Manager, Functional Lead Transfer Pricing, SAP

Michael Streibel
Corporate Tax Department, Head of Transfer Pricing, ABB

Konrad Szpadzik
Deputy Director, Department for Large Business, National Fiscal Administration

Ronald Van Den Brekel
Partner, EMEIA Transfer Pricing Leader - Transfer Pricing & Operating Model Efffectiveness Group, EY

Jan-paul Vestering
AVP, Head of Group Transfer Pricing & Business Models, Nestlé