Join our upcoming Transfer Pricing Event during which we will update you on the recent developments regarding the Taxing of the Digital Economy and Financial Transactions that will take place on Tuesday, 28 January 2020 in Geneva and on Wednesday, 29 January 2020 in Zurich.

Digital Economy
The OECD proposals regarding the Taxing of the Digital Economy are wide-reaching reforms that will have a broad impact on the international tax framework and are not limited to the technology sector or those businesses that might be considered to be highly digitalised. During the events we will discuss the impact of the OECD discussion papers on Swiss companies from a practical perspective and in the light of the discussions held during / after the public consultations organised by the OECD. Furthermore, at our event in Zurich Ronny Rosenblatt from the Swiss State Secretariat for International Finance (SIF) will share his thoughts and a future outlook with us on this topic.

Financial Transactions
Also the new OECD discussion draft on transfer pricing for financial transactions, which is expected to be published prior to the events, will be discussed so that you are directly fully aware of the practical implications the new discussion draft could have. During our event in Geneva Natassia Burkhalter from the Swiss Federal Tax Authorities (SFTA) will share her view on this topic with us.

The events will cover the following topics:

• Summary of the wider discussions held regarding the “Programme of Work for Addressing the Tax Challenges of the Digitalisation of the Economy”, including Pillar I and Pillar II, and a practical future outlook for Swiss companies.
• Impact of the proposals on the international tax framework (e.g. Changes to the OECD TP Guidelines, Double tax treaties, Attributions of profits to PEs, changes to domestic law), including latest country developments.
• Expected OECD discussion draft on the transfer pricing for financial transactions.
• Insights from SIF and SFTA representatives.

Your value in participating

• Receive updates on the latest consultation documents regarding the Taxing of the Digital Economy and the expected OECD discussion draft on transfer pricing for financial transactions.
• Get Deloitte’s as well as a SIF and SFTA representative’s view on the latest developments.
• Be informed about the impact on the international tax framework.

Register here 

If you would like to discuss more on this topic, please reach out to our key contacts below. 

Salim Damji - Partner, Transfer Pricing

Salim Damji joined Deloitte Switzerland as a Transfer Pricing and BMO Partner in our Zurich office from another Big Four firm in Switzerland. Salim has been a Big Four firm’s partner for approximately 14 years. He primarily works with Swiss groups to assist them in developing transfer pricing models which are globally sustainable, Advance Pricing Agreements, Mutual Agreement Processes, and Business Restructuring issues. Salim, who works extensively in the field of Intellectual Property, started his career in the UK, before moving to Switzerland in 2005 and worked in the UK, USA, and Switzerland. He holds degrees from Oxford University and Southampton University. .

Email

Raoul Stocker - Partner, Transfer Pricing

Raoul Stocker is a tax partner with more than 15 years’ experience specifically in international tax litigation such as mutual agreement procedures and advanced pricing agreements. His focus lies on corporate tax planning, cross-border structuring of corporate transactions and businesses, transfer pricing as well as taxation of financial institutions. Raoul is also a lecturer of transfer pricing and tax law at the University of St. Gallen.

Email

 

Martin Krivinskas- Partner, International Tax

Martin Krivinskas is an international tax partner with 19 years experience. Martin works predominantly with large global multinationals, with a particular focus on helping international group’s mitigate tax risk.

Email

Hans Rudolf Habermacher - Partner, Transfer Pricing 

Hans Rudolf habermacher has over 17 years’ of experience in advising clients in Transfer Pricing concepts. He successfully engages with MNCs in various industries in the planning, implementation, documentation & defence of TP concepts. Further he has significant experience in the design and implementation of principal & licensing structures. He is also highly successful in filing and negotiating bilateral APA's (Advanced Pricing Agreements) and mitigating double taxation issues through MAP procedures.

Email