Mutual Agreement Procedure: Competent Authority Relief for Multinational Companies Facing Transfer Pricing Adjustments
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide an overview of the treaty-based mutual agreement procedure (MAP) mechanism for resolving double taxation between countries. Our panel of international dispute resolution specialists will explore tax treaty basics, U.S.-specific strategic considerations, the likelihood of double taxation relief, and other pertinent considerations.
Outline
- Introduction
- Tax treaties and MAP
- U.S.-specific considerations
- Overview of the MAP process
- Evaluating MAP
- Hot topics in MAP
Benefits
The panel will cover these and other critical issues:
- An overview of MAP
- The interplay of tax treaties and MAP cases
- Utilizing MAP to obtain transfer pricing adjustment relief
- Circumstances that warrant MAP consideration
- Examples of MAP utilization and requirements in specific countries
Faculty
Thomas D. Bettge
Senior Manager
KPMG US
Mr. Bettge is a manager with KPMG LLP’s Washington National Tax practice, where he specializes in transfer... | Read More
Mr. Bettge is a manager with KPMG LLP’s Washington National Tax practice, where he specializes in transfer pricing and international tax dispute resolution and planning. He is a co-author of the Warren Gorham & Lamont treatise Transfer Pricing Strategies, as well as an ongoing monthly column in International Tax Review and numerous other articles on transfer pricing and other tax topics. Prior to joining KPMG, Mr. Bettge began his career with the tax practice of a leading law firm. He obtained his J.D. from the Pennsylvania State University Dickinson School of Law, where he graduated first in his class.
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Craig Reeder
Partner
KPMG Canada
Mr. reeder is a Partner at KPMG in Canada’s Greater Toronto Area (GTA) Transfer Pricing practice. He has focused... | Read More
Mr. reeder is a Partner at KPMG in Canada’s Greater Toronto Area (GTA) Transfer Pricing practice. He has focused exclusively on transfer pricing and assisting clients worldwide with an emphasis on dispute resolution and other complex transfer pricing matters. Mr. Reeder has extensive experience working with clients needing to resolve disputes via the Advance Pricing Arrangement (“APA”) program or the Mutual Agreement Procedure (“MAP”) process on a bilateral and multilateral basis. Additionally, he has a deep understanding of Canada Revenue Agency (“CRA”) audit defense and the preparation of contemporaneous transfer pricing documentation. Mr. Reeder has also assisted in preparation of Canadian contemporaneous documentation for various clients, those countries include the US, Switzerland, Korea, Japan, Mexico, UK, and Belgium. He works in many industries but focuses on transfer pricing related matters for the automotive, pharmaceutical, and consumer products industries.
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Phil Roper
Partner
KPMG UK
Mr. Roper has more than 20 years of corporate tax advisory experience, including 5 years working in the pharmaceutical... | Read More
Mr. Roper has more than 20 years of corporate tax advisory experience, including 5 years working in the pharmaceutical industry and over 10 years with KPMG. He assists multinational businesses with setting their transfer pricing policies and resolving tax authority disputes and is KPMG UK’s national lead for transfer pricing quality and technical excellence. Mr. Roper represents KPMG UK at the HMRC Transfer Pricing and Thin Capitalization Forums and is also the UK representative on KPMG’s EMA Transfer Pricing Insights team.
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Lillie Sullivan
Senior Manager
KPMG US
Ms. Sullivan represents multinational enterprises in transfer pricing and international tax controversy... | Read More
Ms. Sullivan represents multinational enterprises in transfer pricing and international tax controversy matters. Her work in transfer pricing dispute resolution largely consists of providing advice related to advanced pricing agreements and competent authority cases. Ms. Sullivan also prepares transfer pricing documentation, advises on intercompany agreements, and assists with transfer pricing and international tax planning and controversy matters. She holds a JD degree from the University of Texas and a BA degree from Southwestern University.
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