Attendance of the event will arm you with essential technical knowledge and planning ideas from authoritative experts on how to minimize your tax exposure, as well as bringing you up to speed with the latest legislative developments and relevant international case law.

Day 1


08:30 - Registration & Coffee

09:00 - Chair’s Opening Remarks

09:10 – Keynote Speech
HMRC speaker under invitation


Setting the Scene
09:55 - Increasing Globalisation: The Tax Challenges
• Profit Allocation Issues - “Everyone wants a bigger slice of the pie”
- Permanent Establishments
- Transfer pricing
- CFC regimes & Territoriality
- Double tax risks
• Restructuring - “Globalisation = Change”
- Big Bang vs. Steady State
- Commerciality vs. Tax
- OECD
- Exit charges
- Future of intangibles
• The Future – “Can tax authorities maintain the status quo?”
- Direct v indirect taxes
- Unitary regimes
- Cross-border dispute resolution

Mike Sufrin
Director of Tax
ROLLS-ROYCE



10:40 Coffee


10:55 - What Next for the CCCTB (Common Consolidated
Corporate Tax Base)?
• Current status of the CCCTB project
• Which entities can opt for the regime?
• Consolidation
• Sharing Mechanism
• Administrative Aspects
• Next steps: Are you ready?

Lluis Fargas
Director of Tax for Europe
ALCOA EUROPE



11:40 – Latest Transfer Pricing Developments
• UK transfer pricing update
• The new Chapters I-III of the OECD Guidelines: a practical perspective
• OECD Intangibles Project update
• Key European developments

Paul Wilmshurst & Alberto Pluviano
Principals
THE BALLANTINE BARBERA GROUP,
A CHARLES RIVER ASSOCIATES COMPANY



12:25 – Industry Case Study -
Operations Restructurings’ –
Exit Taxes from a Business Perspective
• How to optimize exit tax in business restructurings
and avoid negative cash flow impacts
• Case studies: declining license payments for the introduction
of toll manufacturing
• What to consider for determining the transfer price for toll
manufacturer in capital intensive industries
• Involvement of Group Tax in the legal entity budgeting process

Alexandra Dolezel
Head of Tax
BOREALIS AG


13:10 - Lunch


14:15 – Consultation, Consultation, Consultation –
Reforming the UK’s Taxation of Foreign Profits
• Why the UK's CFC rules need to change
• "Competitiveness, stability, protecting the tax base"
- Can the UK achieve all 3?
• A "more territorial" tax system - where to draw the line
• Sticky issues 1: offshore IP
• Sticky issues 2: offshore funding
• 2011 - Interim improvements
• 2011- Foreign branches
• 2012 – Endgame
• A model of tax policymaking?

Zach Citron
Corporate M&A Tax Director
GENERAL ELECTRIC



15:00 – European CFCs Rules -
Update & Comparative Analysis
• New Italian regulation
• Opportunities & comparatives advantages between
European CFC regimes including:
- the Italian CFCs regime
- the German CFCs regime
- the French CFCs regime
• Latest European developments

Aaron Meneghin
Head of Taxation
VALENTINO GROUP


15:45 – Afternoon Refreshments


16:00 – Corporate Redomiciliation – The
Best Route to Minimise Tax Exposure?
• To redomicile or not to redomicile? – Rationale for change
• Principles of design – Thinking beyond tax
• Considerations when selecting a parent company location:
- EU or further afield?
• Case study - The Brit Insurance Holding company relocation
• Comparing tax jurisdictions – what to watch out for
• Insuring the new regime is aligned with your
business’ objectives

Neil Sharman
Head of Tax
BRIT INSURANCE



16:45 – European Tax Case Law - Update and Future Outlook

Hartley Foster
Partner
OLSWANG



17:30 – End of Day One



Day 2


08:30 - Registration & Coffee


09:00 - Litigate or Settle? - The Global Rise of Tax Disputes & Latest Resolution Methods
• HMRC litigation and settlement strategy
• Issues from HMRC perspective
• Issues from taxpayer perspective
• Practical examples, looking at cases
• What are the options? Looking at statistics
• What are the alternatives?
• International trends in alternative dispute resolution (ADR)

Liesl Fichardt
Partner
BERWIN LEIGHTON PAISNER


09:45 – Anti-Avoidance Update
• Recent developments
• FA2010 changes
• Effect of a foreseeable GAAR
• Case law update
• International Experience

Ian Sandles
Executive Director, EMEA Tax
NOMURA INTERNATIONAL


10:30 – Coffee Break


10:45 – Managing Tax Risk
Industry speaker to be announced



11:30 – Trading with IP - Tax Issues for Multinational Businesses
• Withholding taxes; practical risks
• Double Tax Relief
• Permanent Establishment: agency v principal
• Transfer pricing
• Joint ventures
• Non tax risks

David Campkin
Head of Tax
BBC


12:15 - Investing Cross-Border - Tax Considerations, Trends and Current Hot Spots
A high level session on the key international tax considerations involved in portfolio and minority cross-border investments in shares and securities, focusing in particular on the tax position in the country of investment, including:

• Beneficial ownership
• Local withholding
• Capital gains tax
• Double tax treaties
• Global tax developments

Martin Walker
Tax Counsel
CITI


13:00 - Lunch


14:00 Permanent Establishments
The new interpretation of Art. 7 introduces what many tax directors see as radical changes to the profit calculation of permanent establishments within the framework of Art. 5 par.3 OECD MT. This session, organised around an industry case study, will dissect how the new rules are working in practice.

Gilles Roux
Head of Tax
BILFINGER BERGER AG



14:45 Global Indirect Tax Developments
Industry speaker to be announced


15:00 – Afternoon Refreshments



15:15 – Tax Planning for Change – Acquisitions,
Divestments & Reorganisations
Industry speaker to be announced



16:00 – Tax Planning in CEE Countries – Opportunities & Risk Mitigation

Bartjan Zoetmulder
Tax Partner, Head of CEE Team
LOYENS & LOEFF N. V.



16:45 – Tax Aspects of Corporate Treasury
• Accounting issues
• Loan relationships
• Corporate debt and restructuring
• Worldwide debt cap
• Intra-group debt

Roger Muray
Partner, Financial Services
ERNST & YOUNG


17:30 – Chairman’s Closing Remarks & Champagne Draw

David Campkin, Group Tax Director, BBC
Gilles Roux, Group Tax Director, Bilfinger Berger
Roger Muray, Partner, Ernst & Young
Ian Sandles, Director , Nomura International
Bartjan Zoetmulder, Tax Partner, Loyens & Loeff N. V.
Mike Sufrin, Director of Tax, Rolls-Royce
Liesl Fichardt, Partner, Berwin Leighton Paisner
Helen Blenkinsop, Group Tax Manager, Informa Group Plc
Aaron Meneghin, Head of Tax, Valentino Group
Hartley Foster, Partner, Olswang
Alberto Pluviano, Principal, Charles River Associates
Paul Wilmshurst, Principal, Charles River Associates
Martin Walker, Tax Counsel, CITI
Lluis Fargas, Director Tax Europe, Alcoa Europe
Neil Sharman, Head of Tax, Brit Insurance
Alexandra Dolezel, Head of Tax, Borealis
Zach Citron, M&A Tax Director, General Electric
Jonathan Leigh Pemberton, Deputy Director Business International, HMRC
Alan Macpherson, Partner, Deloitte