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Overview:

The economic downturn brought by the COVID-19 pandemic has profoundly impacted the transfer pricing landscape. Multinational enterprises (MNEs) are dealing with serious transfer prices issues, supply chain disruptions, and restructuring expenses. In response to these growing repercussions, the Organization for Economic Co-operation and Development (OECD) recently published guidance on transfer pricing policies and clarified the application of the arm’s length principle. It also underscored the compliance challenges faced by MNEs.

With the changing tides, businesses must make sound management decisions to navigate transfer pricing consequences. Furthermore, business and tax authorities must be thorough in assessing pricing arrangement adjustments to mitigate potential tax disputes.

Listen as transfer pricing experts Shaun T. MacIsaac Q.C. (PMR Law) and Anna Soubbotina (Charles River Associates) examine the latest trends and updates in transfer pricing. Speakers will present common transfer pricing issues and tax challenges companies face today. They will also offer best practices in documentation and calculation amid the COVID-19 pandemic.

This LIVE Webcast will discuss the following:

  • Transfer Pricing basic principles
  • COVID-19 implications
  • Policy responses to COVID-19
  • OECD Pillar One and Pillar Two
  • The decision in Coca-Cola v Commissioner as a cautionary tale

Learning Objective:

  • Determine the pandemic’s implications on transfer pricing, the OECD BEPS and pillar one and two initiatives, and the key takeaways from Coca-Cola and Cameco cases

Credit:

Course Level:

Intermediate

 

Advance Preparation:

Print and review course materials

 

Method of Presentation:

On-demand Webcast (CLE); Group-Internet Based

 

Prerequisite:

General knowledge of transfer pricing

 

Course Code:

149335

 

NASBA Field of Study:

Taxes – Technical

 

NY Category of CLE Credit:

Areas of Professional Practice

 

Total Credits:

1.5 CLE

1.5 CPE (Not eligible for QAS (On-demand) CPE credits)


CLE State Requirements:

https://knowledgewebcasts.com/cle-state-requirements/

Speaker Panel:

Shaun T. MacIsaac, Q.C., Principal
PMR Law

Over the last twenty years, Shaun T. MacIsaac, Q.C., has represented taxpayers in transfer pricing disputes, and has appeared as lead counsel a number of transfer pricing litigation cases. Mr. MacIsaac was counsel in the case of Alberta Printed Circuits Ltd. v. Her Majesty The Queen, decided by the Tax Court of Canada in April of 2011 that made many practical contributions to the transfer pricing field, including the use and proof of OECD methodologies, proof of the value of intangibles, and the relationship between the OECD Guidelines and domestic tax laws. He has also been counsel in other Canadian transfer pricing cases, including a case brought to the Federal Court of Appeal. He has resolved leading oil and gas transfer pricing tax appeal cases by concluding settlements with counsel to the Canada Revenue Agency in 2020.

Shaun MacIsaac’s practice involves advising clients in the management and resolution of transfer pricing disputes at the audit, internal appeals, and tax appeals to the Tax Court of Canada. He is currently involved in appeals to the Tax Court of Canada in transfer pricing matters.

Anna Soubbotina, Principal
Charles River Associates

Anna Soubbotina is a Transfer Pricing Principal with Charles River Associates, based in New York. Ms. Soubbotina has guided companies through the life cycle of their controlled transactions: from international expansion to business and regulatory change, through to effective controversy resolution. Ms. Soubbotina leverages her experience working with Fortune 100 companies to guide clients through business change and disruption, such as an IPO, global supply chain expansion/contraction, market shocks, profitability and cost changes. Companies going through business transformation need to consider the cross functional implications of their transactions. Ms. Soubbotina’s advisory approach allows flexibility to customize every project and team to bridge the gap between regulatory constraints and business needs.

Agenda:

Shaun T. MacIsaac, Q.C.Principal

PMR Law

AND

Anna Soubbotina, Principal

Charles River Associates

  • The Basic principles
  • Pandemic and Transfer Pricing
  • The OECD BEPS and Pillar One and Two Initiatives
  • The Coca-Cola case

Date & Time:

Wednesday, March 10, 2021

12:00 pm to 1:30 pm (ET)

Materials:

Download Course Materials

Who Should Attend:

  • Transfer Pricing Lawyers
  • Tax Lawyers
  • Transfer Pricing Advisers
  • Transfer Pricing Managers
  • Chief Financial Officers
  • Financial Reporting Officers
  • Financial Management Officers
  • Tax Managers and Directors

SPEAKERS

Shaun T. MacIsaac, Q.C.Principal
PMR Law
Anna SoubbotinaPrincipal
Charles River Associates

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