Advance Pricing Agreements (APAs) can be a highly effective tool available to taxpayers for managing potential transfer pricing risks. Specifically, APAs provide taxpayers with assurance that tax authorities will not audit and make adjustments to their transfer prices in the future.
Via range of case studies, the panel will share their extensive experience on APAs, focusing in particular on the APA environment in Hong Kong, China, Japan and the US.
The following key topics will be addressed:
• When are APAs a realistic, viable alternative for managing transfer pricing risks?
• What strategies are most successful for securing an APA and why do they 'work'?
• How do you get tax authorities "interested" in entering into APA negotiations?
• How may the APA programs of the respective jurisdictions develop in the coming years?
This roundtable is suited to Asian professionals and organisations with operations in China, Japan and Hong Kong with potential transfer pricing risks.
Kari Pahlman, Principal, Asia Pacific Leader, Global Transfer Pricing Servcies, KPMG China
Kari leads more than 600 KPMG transfer pricing professionals across the Asia Pacific region and is part of KPMG's global management team for the transfer pricing service line. He has over twelve years of experience in tax and financial advisory in relation to international taxation, transfer pricing and valuations. He specialises in various economic advisory assignments in relation to transfer pricing, tax effective supply chain management and asset valuations and has served as an engagement leader for numerous regional and global projects in these areas.
John Kondos, Partner, Financial Services Asia Pacific Leader, Global Transfer Pricing Services, KPMG China
John is based in Hong Kong and leads the KPMG Asia Pacific regional Financial Services Transfer Pricing team. Having lived and worked in Asia for over 14 years in Japan, China and HK, John has extensive experience specialising in asset and fund management, banking and capital markets, insurance, treasury and intra-group service transactions. He has assisted clients in a significant number of tax/transfer pricing audit defense and competent authority cases and he has completed a large number of financial services APAs across the Asia Pacific region.
David Chamberlain, Director, Global Transfer Pricing Services, KPMG China
David, based in Beijing, brings 20 years of experience in transfer pricing, most of it in San Francisco and Silicon Valley in California, USA. Prior to joining KPMG, he was a Team Leader with the US APA Program where he negotiated numerous APAs with taxpayers ranging from small businesses to billion-dollar multinationals in a wide variety of industries, dealing with numerous countries throughout Asia and Europe. David specialised in high technology and R&D cost sharing cases, and was involved in several bilateral APAs between the US and China.