Tue, Jul 9, 2019
The inaugural TP Minds Canada conference was held on June 11-12, 2019 in Toronto, Canada. It brought together experts and delegates from diverse fields of practice, including professional services firms, multinational taxpayers, law firms, the Canada Revenue Agency (CRA), the Organisation for Economic Co-operation and Development (OECD), Internal Revenue Service (IRS), European Commission, International Monetary Fund (IMF) and the Tax Court of Canada.
Hot topics for discussion at the conference included taxation of the digital economy, approaches for “hard to value intangibles”, the adoption of technology within the tax department, and lessons learned from country-by-country reporting.
The conference began with a panel of global transfer pricing policy leaders, including representatives from the OECD, CRA and IMF, moderated by Matt Billings of Duff & Phelps’ transfer pricing practice in Toronto. Topics of discussion included:
Many of the panel’s responses touched on the difficulty of achieving global consensus, differing priorities between jurisdictions, the high stakes for taxpayers and national governments and the likelihood for increasing numbers of tax disputes related to transfer pricing.
Two other panels also featured speakers from the Duff & Phelps’ transfer pricing group.
Matt Billings moderated a panel of senior tax executives who spoke of their experience with transfer pricing dispute resolution. Topics of discussion included:
Many of the responses touched on the benefits of treating auditors with respect, relying on advisors, developing an audit strategy in advance and helping auditors understand the taxpayer’s broader business context.
Susan Fickling-Munge from the firm’s Chicago office participated on a panel with other transfer pricing professionals to discuss the shifting landscape of defining and valuing intangibles. Topics of discussion included:
The panelists’ responses emphasized the increased scrutiny of intangible analyses by taxing authorities and the heightened importance for taxpayers to understand the potential risks or exposures surrounding their IP landscape.
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