Transfer Pricing Webinar on 25 August 2020: (L)IBOR Transition and Intra-Group Financing – Transfer Pricing Aspects of an Unprecedented Transformation

The Transfer Pricing Webinarwas hosted on Tuesday, 25 August 2020, 10.00am (CET) to discuss recent developments on the upcoming (L)IBOR transition and the resulting implications from a transfer pricing perspective.

About the webinar:

Interbank Offered Rates (IBORs) such as LIBOR (London Interbank Offer Rate) are deeply rooted in the financial system. They are estimated to underpin USD 350 trillion of financial products (e.g. bonds, derivatives, loans, mortgages) and serve as the basis for many contracts and valuations.

Following the 2007-08 financial crisis and a number of manipulation scandals, it became apparent that these reference rates were inadequate. In 2017, the Financial Conduct Authority (FCA), the UK body that regulates LIBOR, announced that the benchmark will be discontinued at the end of 2021. This announcement triggered what is now known as the IBOR transition.

Defining Alternative Reference Rates (ARRs), such as the Secured Overnight Financing Rate (SOFR) and the Swiss Average Rate Overnight (SARON), has been the first step in the IBOR transition. However, differences between ARRs and IBORs in terms of tenor, security and credit risk are creating uncertainty and complexity in what is seen as one of the biggest-ever transformation programs in the financial system.

From a transfer pricing perspective, the IBOR transition and the resulting amendments to existing contracts and valuations may give rise to issues to consider, such as tax and transfer pricing implications of amendments to existing contracts, step-ups/downs in rates during the life of existing contracts, and the arm’s length market value of arrangements.

To discuss this hot topic, the Deloitte team will be joined by Thomas Hug, Deputy Head Group Tax at Julius Baer Group.

Webinar agenda

10.00am to 11am CET:

• Greetings and introductions
• High-level overview of treasury and commercial considerations
• Overview of the key transfer pricing implications
• Industry perspective
• Q&A and closing

Speakers

Thomas Hug - Deputy Head Group Tax, Julius Bär Group
Salim Damji - Partner, Transfer Pricing and Value Chain Alignment, Deloitte Switzerland
Martin Krivinskas - Partner, Transfer Pricing and Value Chain Alignment, Deloitte Switzerland
Georgy Galumov -Director, Transfer Pricing and Value Chain Alignment, Deloitte Switzerland
Peter Nobs - Director, Head Treasury & Debt Advisory Services, Financial Advisory, Deloitte Switzerland
Xavier Tinguely - Manager, Transfer Pricing and Value Chain Alignment, Deloitte Switzerland

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

Key contacts

Salim Damji - Partner, Transfer Pricing and Value Chain Alignment

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. .

Martin Krivinskas - Transfer Pricing and Value Chain Alignment

Martin is an international tax partner with 20 years experience working on international tax matters. He has worked extensively with global multinationals, with a particular focus on helping international group’s mitigate tax risk and manage their effective tax rates. Martin has significant experience of supporting clients with a wide range of transfer pricing and international tax matters and is part of Deloitte` s Global Value Chain Alignment leadership team. Martin`s clients are predominantly in the life sciences, industrial products and consumer products industries.

Martin is a Chartered Accountant and a member of the Chartered Institute of Taxation

George Galumov - Director, Transfer Pricing and Value Chain Alignment

George has more than 12 years of transfer pricing experience covering tax and transfer pricing aspects of various intra-group transactions, including business model and transaction flow design, M&A activity, as well as more mainstream transfer pricing documentation and planning engagements. George has worked with a number of leading multinational corporations including FTSE 100 companies, leading energy and resources businesses, financial services institutions and private equity owned businesses. George has an MSc in Energy Trade and Finance from Cass Business School and is a holder of the Chartered Financial Analyst (CFA) designation.

Peter Nobs - Director, Director, Head Treasury & Debt Advisory Services

Peter is a Director with more than 30 years of experience in Treasury Advisory for corporate clients across several industries. Prior to Deloitte Peter worked as Managing Partner in a Treasury consultancy company and with another Big 4. In addition, Peter held several Treasury executive functions with large multinationals. Peter’s primary focus is on strategic and operational treasury aspects of his clients that require innovative, forward-looking solutions based on newest technology available also combining Fintech products. He advised a multitude of mid and large caps in reorganising treasury functions, processes and systems usage.

Xavier Tinguely - Manager, Transfer Pricing and Value Chain Alignment

Xavier is a manager in the Tax & Legal practice of Deloitte Switzerland with more than 10 years of professional experience. After a PhD in economics between Switzerland and the U.S., Xavier started his career in Transfer Pricing in Geneva. He then joined the re/insurance industry where he was a Vice President in Corporate Development and Underwriting teams in Zurich, New York and Toronto. Xavier relocated to Switzerland in 2020 to join Deloitte as a Transfer Pricing Manager. His practice consists out of advising multinational companies in the field of Transfer Pricing and Business Optimization. More specifically, he focuses on transfer pricing documentation, economic analysis, business restructuring, intellectual property planning, and valuation.

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