Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.

nl _______________________________

Global Transfer Pricing Seminar

The future of Tax Efficient Supply Chains

23 November 2012 Amsterdam, the Netherlands

To register please email: maaike.vanderaa@vmwtaxand.nl SEMINAR PROGRAM Friday 23 November 2012

Start 08.15

End : 08.45

Program Registration

Speaker__ All

08.45

: 09.00

Welcome / Overall Introduction

Olaf Smits & Rutger Hafkenscheid (Taxand Netherlands)

09.00

: 09.15

Introduction

Antoine Glaize (Taxand France) Taxand Global Transfer Pricing Service Line Leader Shiv Mahalingham, Tom McFarlane & Stuart Ells (Taxand UK)

09.15

: 10.00

Discover what commercial substance and audit strategies are used by tax authorities to review your supply chain model Find out which strategies maximize efficiency, what the Tax Authorities' approach to audits are and how to mitigate potential adjustments and importance of commercial factors

10.00

: 10.30

Coffee break*

All

10.30

: 11.15

Is your business model aligned with the supply chain of the future? We uncover developments in supply chain design from a non-tax perspective

Hans Moonen, Consultant at Logica Business Consulting & Assistant Professor at University of Twente

Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.nl _______________________________

11.15

: 12.00

Indirect tax and customs implications of developments in the supply chain

Werner Engelen, EMEA VAT manager Hewlett-Packard & Paul Bakker (Taxand Netherlands) All

12.00

: 01.15

Lunch*

01.15

: 02.00

Tax Authorities' view on tax efficient supply chain models

Niels Smetsers, head of the APA Team of the Dutch Tax Authorities

02.00

: 02.45

Permanent Establishment panel discussion Recent case-law developments

Antoine Glaize (Taxand France), Mario Ortega Calle (Taxand Spain) & Jim Wilson (Taxand Canada) All

02.45

: 03.30

Tea break*

03.30

: 04.15

Intellectual property briefing on OECD developments and panel discussion

Paul Morton, Reed Elsevier, ngel Calleja Crespo (Taxand Spain), Mukesh Butani (Taxand India) & Stephen Labrum (Taxand UK) Olaf Smits & Rutger Hafkenscheid (Taxand Netherlands)

04.15

: 04.30

Q&A, Wrap up & Close

* During breaks, Christoph Kromer (Taxand Germany) will host demonstrations showing the transfer pricing documentation application, developed by Taxand Germany. In addition of these demonstrations, bespoke client meetings can be organized on request. BESPOKE CLIENT MEETINGS, 22 & 23 November 2012 As well as attending the seminar, bespoke client meetings can be organized with Taxanders from around the world to discuss your specific tax issues on November 22 & 23. To reserve your bespoke discussion or demonstration please email Maaike van der Aa at maaike.vanderaa@vmwtaxand.nl to pre-book your meeting, to suit your requirements, with one or more Taxand countries among others: Canada, France, Germany, Greece, Ireland, Netherlands, Portugal, Russia, Spain, UK and many more.

Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.nl _______________________________

Speaker Biographies - External Speakers Hans Moonen is a consultant at Logica Business Consulting within the Transport & Logistics domain. This is combined with a one day a week position at the University of Twente. In both professions Hans core focus is on smart & sustainable logistics and transport; in other words: how to organize supply chains and transport operations in smarter & more sustainable manners. The past twelve years, Hans has operated on the interplay between supply chain management, process change and innovative software. Before his current professions, Hans worked at enterprise software vendor Baan, followed by a position at Erasmus University, where he obtained his PhD degree. In 2000 Werner Engelen joined Hewlett-Packard, where he is responsible for the VAT within Europe as a VAT Manager EMEA. Werner graduated as a Certifying Accountant in 1996. Subsequently he accomplished VAT at the University of Amsterdam in 2002 and thereafter obtained a Post-Master Indirect Tax at the Erasmus University. Besides his work for Hewlett-Packard, he provides on a regularly basis lectures on VAT related topics for amongst others, Marcus Evans and Fenedex.

Hans Moonen Logica Business Consulting and the University of Twente The Netherlands

Werner Engelen Hewlett-Packard The Netherlands

Niels Smetsers Dutch Tax Authority The Netherlands

Niels Smetsers is head of the APA Team of the Dutch Tax Authorities and contact person for potential foreign investors. He is working at the Dutch Tax Authority for over twelve years and primarily focusses on transfer pricing.

Paul Morton Reed Elsevier The United Kingdom

Paul Morton is Head of Group Tax at Reed Elsevier Group plc where he leads a team of 26 tax professionals based in London, Boston, Amsterdam and Singapore. Reed Elsevier operates businesses in more than 90 countries including LexisNexis. Prior to this Paul was head of the global downstream business of Royal Dutch Shell. While at Shell he also fulfilled a number of other roles including European Internal Audit Manager, Head of Tax for Shell UK Exploration and Production, adviser to the global exploration and production business among others. Prior to that he was a tax manager at KPMG and he originally trained as a tax inspector in the UK Inland Revenue.

Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.nl _______________________________

Speaker Biographies - Taxand Speakers Antoine is based in Taxand France where he is leader of Arsene Taxands transfer pricing service. He leads Taxands global transfer pricing team. Antoine joined the French Ministry of Economy, Finance and Industry in 1991 where, from 1997, he was responsible for transfer pricing and APA's as Head of The Tax Audit Office and The Office of International Affairs of the General Management Division of The French Tax authorities. In 2000 he joined Andersen as partner and between 2003 and 2006 Antoine was in charge of the French Transfer Pricing practice of Ernst & Young. Olaf is based in Taxand Netherlands where he is head of VMW Taxand's transfer pricing team. Olaf serves clients in all aspects of transfer pricing including transfer pricing documentation, economic and financial analyses, APAs, audit managements, business restructurings and transfer pricing model design, review and optimization. Prior to joining Taxand, Olaf worked in Hewlett-Packard's transfer pricing team.

Antoine Glaize France T: +33 623 088 006 E: Antoine.glaize@arsenetaxand.com

Olaf Smits The Netherlands T: +31 20 301 8029 E: olaf.smits@ vmwtaxand.nl

Rutger Hafkenscheid The Netherlands T: +31 20 301 80 29 E: rutger.hafkenscheid@ vmwtaxand.nl

Rutger is based in Taxand Netherlands where he works at VMW Taxand. He is also the Dutch Key member of Taxands global transfer pricing team. Rutger advises large and medium sized companies on transfer pricing strategies, implementation, audit defense, dispute resolution and litigation. As tax and transfer pricing decisions often involve uncertainty, Rutger has developed an innovative decision analysis methodology that helps to evaluate the likelihood of the expected financial outcomes of a tax and transfer pricing decisions.

Shiv Mahalingham The United Kingdom T: +44 207 715 5234 E: smahalingam@alvarez andmarsal.com

Shiv is based in Taxand UK where he is a Managing Director and Co-founder of Alvarez & Marsal Taxand UK. He is the key UK member of Taxands global transfer pricing team. Shiv has deep industry expertise and experience across real estate, entertainment, retail, pharmaceutical, manufacturing, technology, telecommunications and energy.

Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.nl _______________________________

Tom McFarlane The United Kingdom T: +44 207 072 3201 E: tmcfarlane@alvarez andmarsal.com

Tom is based in Taxand UK where he is a Managing Director with Alvarez & Marsal Taxand UK in London. He leads the Tax Efficient Supply Chain Management practice and brings nine years of experience in implementing principal structures for multinationals around the globe. Tom has worked with clients across a range of industries, including consumer products, retail, mining, and oil and gas. He has successfully advised on, implemented and project-managed some of the largest business reorganizations in Europe.

Stuart Ells The United Kingdom T: +44 207 715 5200 E: sells@alvarez andmarsall.com

Stuart is based in Taxand UK where he is a Managing Director with Alvarez & Marsal Taxand UK in London. He brings over twenty years of corporate experience in the media and entertainment sector. Stuart has served as CFO, COO and CEO in a range of companies involved in filmed entertainment, TV production, recorded music, music publishing, theatre production and theatre management. He has also led the sale out of Chapter 11 of a leading independent record company and music publisher.

Paul Bakker The Netherlands T: +31 20 575 09 07 E: paul.bakker@ vmwtaxand.nl

Paul is based in Taxand Netherlands where he works at VMW Taxand. He is also the coordinator of Taxand's Global Indirect Tax Service Line. Paul has been advising national and international companies for over ten years on indirect and procedural tax-related matters, including vehicle registration tax, excise duties and gambling tax. He also has vast experience in coordinating global and European projects on the VAT treatment of activities in different jurisdictions. In addition to advising clients, Paul litigates on behalf of companies in civil and tax matters brought before the Dutch courts and assists clients with voluntary disclosures. Mario is based in Taxand Spain, where he is the Principal Associate in the Transfer Service Line of Garrigues Taxand. He has extensive knowledge and experience in designing and implementing transfer pricing structures, particularly on an international level, supply chain analyses and reorganizations, business restructurings, mutual agreement procedures, APA's, audits and global documentation in relation to multinational groups operating in different economic sectors. Mario habitually participates in forums and conferences and has published different articles in various specialized magazines. He also lectures on transfer pricing for numerous Masters degree programs.

Mario Ortega Calle Spain T: +34 91 514 52 00 E: mario.ortega.calle@ garrigues.com

Hosted by: Taxand Netherlands Contact: Maaike van der Aa T. +31 20 301 80 38 E. Maaike.vanderaa@vmwtaxand.nl _______________________________

Jim Wilson Canada T: +1 613 786 0196 E: jim.wilson@ gowlings.com

Jim Wilson is based in Taxand Canada. He is partner of Gowlings and works in conjunction with the National Tax Practice Group to help companies optimize their global tax position and reduce exposure to audit assessments through tax planning and implementation strategies. Jim has gained experience with rulings from working at the Canada Revenue Agency for 32 years.

ngel Calleja Crespo Spain T: +34 91 514 52 00 E: angelcalleja@ garrigues.com

ngel Calleja Crespo is based in Taxand Spain. He is Partner at Garrigues Taxand, the largest Spanish tax and legal services firm. He has experience in advising large multinationals on transfer pricing, international tax, international negotiations and M&A issues. ngel occupied positions as advisor for the Ministry of Economy and Finance and professor and lecturer for several international widely known law schools.

Mukesh Butani India T: +91 124 339 5010 E: mukesh.butani@ bmrlegal.in

Mukesh Butani is based in Taxand India. He is Managing Partner of BMR Legal Taxand. Mukesh is an expert in international taxation and transfer pricing and has experience in advising Fortune 500 multinationals and Indian businesses on a wide range of matters. He previously held the positions of national Tax Director and international Tax Partner.

Stephen Labrum The United Kingdom T: +44 20 7663 0443 E: slabrum@alvarez andmarsal.com

Steve is based in Taxand UK where he is a Managing Director with Alvarez & Marsal Taxand UK in London. His primary area of concentration is transfer pricing, but he also has considerable experience in the fields of tax efficient supply chain management and valuations. His experience covers transfer pricing policy design, business restructuring, global documentation, implementation and resolving and preventing controversy with Tax Authorities.