Duff & Phelps to Sponsor and Speak at TP Minds International 2020

Calendar July 13-15, 2020

The Duff & Phelps Transfer Pricing practice will be an exhibitor at the 2020 TP Minds International Conference which will be held virtually on July 13-15.

Learn more about TP Minds International.

The annual conference is the world’s largest gathering of transfer pricing minds. In-house transfer pricing leaders, top specialist advisers and policy makers will provide key insights on trending topics, including the Pillar One impact on transfer pricing, global anti-base erosion proposals under Pillar Two, and benchmarking and valuation of intangibles.

Ted Keen, Managing Director and Leader of Duff & Phelps’ European Transfer Pricing practice, will present on the session titled, “TP Case Law Deep Dive”. On September 24, 2019, the General Court of the European Union released its decisions on two major State Aid cases. In the first case, dealing with Fiat Chrysler Finance Europe (FFT) in Luxembourg, the General Court upheld the European Commission’s decision that the Luxembourg tax authority’s ruling granted to FFT constituted State Aid. However, in the second case, the General Court concluded that the Commission was unable to demonstrate that the Dutch tax authority’s ruling for Starbucks Manufacturing EMEA BV (SMBV) constituted an advantage, and therefore, annulled the Commission’s decision on SMBV. As both Fiat and Starbucks employed a Transaction Net Margin Method (TNMM) for determining arm’s length remuneration for the entities in question, an exploration of why the taxpayer’s application of TNMM was upheld in one instance but overruled in the other is instructive.

Topics

  • A (very) brief review of the Transaction Net Margin Method;
  • The facts of the Fiat case;
  • Fiat’s misapplication of TNMM;
  • The facts of the Starbucks case;
  • Starbucks application of the TNMM;
  • The EC’s criticism and application of an alternative CUP method;
  • The EC’s misapplication of the CUP method; and
  • Implications for other transfer pricing and State Aid cases.

As a premier partner, Duff & Phelps is pleased to offer 50% off registration with VIP code FKW53986.

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