October 3, 1997

The National Foreign Trade Council Foundation Sponsors Conference On Foreign Transfer Pricing

United States' Major Trading Partners Developing New Tax Initiatives

Washington, D.C. - Responding to the acceleration of transfer pricing enforcement in other countries and the continued expansion of U.S. multinationals doing business overseas, the National Foreign Trade Council Foundation will sponsor a conference focusing on "Foreign Transfer Pricing Requirements And Competent Authority/APA Update." The conference will be held on October 28th - 29th at the Watergate Hotel in Washington, D.C. Fred F. Murray, Vice President for Tax Policy, of the National Foreign Trade Council will co-Chair the conference with Robert T. Cole, partner and Chair of the International Tax Practice Group at Alston & Bird LLP. Bob Cole stated, "Any U.S. multinational which has in place a transfer pricing policy designed solely to satisfy its U.S. requirements is making a big mistake. It must also satisfy the requirements of more and more foreign countries which are following the lead of the U.S. by enhancing their transfer pricing requirements in an effort to increase revenue. In this day and age only a balanced transfer pricing strategy will work." The two day conference will present detailed information on the current changes in the transfer pricing requirements of four of the United States' major trading partners: Canada, Germany, Japan and the United Kingdom. High-ranking officials and audit officers from these countries will discuss international tax planning, audits, and domestic and international dispute resolution. Featured speakers and some of the issues they will address include: Japan: Hidekado Miyaji, Director, Mutual Agreement Procedure, National Tax Administration Japan is increasing the number of transfer pricing auditors and dramatically increasing transfer pricing adjustments. Canada: Pierre St. Laurent, Director, International Tax Directorate, and J.C. Chandani, International Auditor, of Revenue Canada. Canada is in the process of developing new requirements. Announced new requirements September 11, 1997, its new tax rules will increase the amount of documentation required for transfer pricing and impose penalties exceeding those of the U.S. Germany: Professor Dr. Berndt Runge, Head of the Division of International Taxation, Federal Ministry of Finance United Kingdom: Ronald Haigh, Deputy Director, International Compliance, Inland Revenue Not to be outdone, the U.K. is currently developing new requirements. United States: Internal Revenue Service officials
John Lyons, Richard Barrett and Steven A. Musher. In addition, the OECD has just issued guidelines on Cost Contribution Arrangements as they relate to transfer pricing agreements. The National Foreign Trade Council (NFTC) is the oldest and largest U.S. association of businesses devoted to international trade and tax matters. Its 550 members include the largest U.S. manufacturing companies and many of the largest U.S. banks. The National Foreign Trade Council Foundation, a non-profit organization, is the educational arm of the NFTC.
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