We are delighted to invite you to this year’s KPMG Meijburg & Co Transfer Pricing seminar, which will take place on November 9, 2023, at our Amstelveen office.
As always, our goal is to update you on the latest Transfer Pricing developments and to share our specialist insights into several relevant topics.
This year’s plenary session will focus on APAs and current developments such as Amount B, which we will discuss with you and two representatives of the Dutch tax authorities: Paul Klaassen, Head of the APA team, and Vincent Sluijter. This will be followed by a panel discussion with mr. Klaasen, a number of clients and our Meijburg specialists.
The second part of the event consists of break-out sessions, providing a more in-depth look into other recent Transfer Pricing developments, such as Treasury, TP Controversy and a deep-dive into Amount B.
Program
13:30 Registration and light refreshments
14:00 Plenary session
15:00 Panel with Q&A
15:45 Break
16:00 Break-out sessions 1
16:45 Break-out sessions 2
17:30 Drinks, bites, and networking
Panelists
Paul Klaassen, Head of Advance Pricing Agreements, Dutch Tax Authority
Chris Runge, Global Head of Transfer Pricing and Tax Technology, Shell
Hans Geluk, Global Transfer Pricing Manager, Danone
Kathy Lim, Partner Transfer Pricing, KPMG Belgium
Eefje Lemmens, Director Transfer Pricing, Meijburg & Co
Break-out session A: Transfer pricing for the treasury center: Latest trends from our practice by Eduard Sporken (Director Transfer pricing), Valentin Krustev (Director Transfer pricing), and Janneke Versantvoort (Senior Manager Transfer Pricing)
The transfer pricing regulatory framework for intra-group treasury transactions has shifted from the traditional focus on pricing to now also include treasury’s broader role in the value chain. This broadened perspective raises new questions about how a treasury center should be remunerated for its core activities (e.g., raising external financing, providing intra-group funding, pooling and investing excess cash, hedging and risk management) and whether the treasury is even entitled to any non-routine returns in the first place. If it is, one of the core questions to address is what level of commercial equity is to be maintained in respect of the intra-group financing arrangements on the balance sheet.
We will offer some practical insights on what transfer pricing policies may fit different treasury center fact patterns and discuss some feasible ways to implement the appropriate policy.
Break-out session B: Amount B – in-depth look by Jaap Reyneveld (Partner Transfer Pricing) and Sayee Gomathy Ramaswamy (Tax Manager Transfer Pricing).
You have probably read about Pillar 1 – Amount B, but what does it mean? And more importantly, what does it mean for your company? In this break-out session, we will take an in-depth look at the Amount B proposal: its scope, its exceptions, its margins and its suggested step plan, and discuss the inherent opportunities and difficulties as we see them. We will also show you how to model the impact that Amount B may have on your group's local results.
Break-out session C: Transfer pricing controversy, and lessons learned from recent case law by Eefje Lemmens (Director Transfer Pricing), Flor Snel (Tax Manager Transfer Pricing) and Rian Waaijer (Senior Manager Tax Controversy).
Over recent years, transfer pricing controversy cases have increased materially; not only in the Netherlands, but also abroad. This not only results in increasing MAP and arbitration cases, but also in an increase of (Dutch) transfer pricing case law.
In this session we’ll dive deeper into the lessons learned from these recent cases. Moreover, we’ll explore general best practices, when a tax audit discussion threatens.
