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US-Japan Transactions - New APA/MAP environment under BEPS
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Live Webcast
Date: September 30, 2015
Time: 10:00 AM - 11:30 AM EDT
CPE: 1.5


Description:

The IRS, on August 12, 2015, issued new procedures on Advance Pricing Agreement (“APA”) and Mutual Agreement Procedures (“MAP”), which impact US-Japan transfer pricing matters. In certain respects, the new guidance is influenced by the current global tax environment, including the Organization for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project.

In Japan, the tax policies have been aligned with OECD initiatives: the Authorized OECD Approach for income attribution to branches will be implemented from April 1, 2016; and it is expected that the BEPS actions such as country-by-country reporting, master files/local files would be implemented soon through future tax reform process.

Join specialists from PwC's Transfer Pricing practices in the US and Japan to learn about the latest environment for APA and MAP as we move to the post-BEPS world.


Speakers:

Mike Danilack, PwC US Partner, Transfer Pricing and Dispute Resolution, and former Deputy Commissioner Large Business and International of IRS
Carolyn Fanaroff, PwC US Managing Director, Transfer Pricing and Dispute Resolution
Takeki Nagafuji, PwC Japan Transfer Pricing Partner (Specializes on Japan-US transactions)

Moderators:

Takaaki Tokuhiro, PwC US Tax Partner
Junko Yamato, PwC US Transfer Pricing Principal