Global

Weighing the arguments – where is the new normal in transfer pricing? 

The arm’s length principle on trial

At KPMG's 2013 GTPS Technical Forum in a courtroom setting, the arm's length principle was on trial.


Testimonies were heard and the over 375 delegates at the Forum, as the jury, informed the verdict.



The Highlights

Welcome to the trial

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The videos

Welcome to the trial

Welcome to the trial

Sean Foley, KPMG's Head of Global Transfer Pricing Services welcomes the GTPS Technical Forum participants to the arm's length principle on trial.


The case

The case

The stage is set with introductions from the judge and opening statements from the prosecutor and the defender.


Witness #1

Witness #1

Suffering personal anguish due to the arm's length principle.


Witness #2

Witness #2

Spokesperson for the developing world.


Witness #3

Witness #3

The voice of the OECD.


Witness #4

Witness #4

Arm's length principle realist.


Witness #5

Witness #5

The voice of businesses.


Witness #6

Witness #6

A practical perspective.


The closing statements and verdict

The verdict

The judge requests closing statements from the defender and prosecutor before the jury votes.


 

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The cast

Judge


John Neighbour, Deputy Global Leader for Global Transfer Pricing Services, Partner, KPMG in the UK


The right-honorable judge


 

Defender


Montserrat Trapé Viladomat, EMA Lead Partner, Global Transfer Pricing Services, KPMG in Spain


The passionate defender


Prosecutor


François Vincent, Fidal*


The determined prosecutor


Witness #1


Michael Durst, Senior Counsel, Steptoe & Johnson


Suffering personal anguish due to the arm's length principle


Witness #2


Alpana Saksena, Director, Global Transfer Pricing Services, KPMG in India


Spokesperson for the developing world


Witness #3


Richard Parry, Head of the Global Relations Division in the Centre for Tax Policy and Administration, OECD


The voice of the OECD


Witness #4


Matthias Kaut,  KPMG's Head of Global Value Chain Management


Arm's length principle realist


Witness  #5


Matt  Frank, Senior Tax Counsel, Transfer Pricing, General Electric


The voice of businesses


Witness #6


Brian Trauman, KPMG's Head of Global Transfer Pricing Dispute Resolution, Head of Transfer Pricing, KPMG in the US


A practical perspective


*(Fidal is an independent legal entity separate from KPMG International and KPMG member firms)

 

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2013 KPMG EMA Tax Summit
30 September 2 October
Berlin, Germany

 

Preparing for the New Normal

John Neighbour
Hear about the new Global policy agenda from John Neighbour, Deputy Leader of KPMG's Global Transfer Pricing Leader.

Tax Views - KPMG’s 2013 EMA Tax Summit

At KPMG's 2013 EMA Tax Summit we ask the hard questions, share our points of view and welcome you to the conversations.

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If you have any questions regarding the Summit arrangements, please contact infotaxsummit@kpmg.com.

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