European Commission`s Joint Transfer Pricing Forum

Tax Policy Bulletin
European Commission’s Joint
Transfer Pricing Forum mandate
and new composition confirmed
10 June 2015
In brief
On 12 May 2015, the Director-General for Taxation and Customs Union appointed the Members and the
Chairperson of the EU Joint Transfer Pricing Forum (JTPF) for the next two year mandate starting on 1
April 2015 till 30 March 2017. For the first time since its set up in 2002, the European Commission has
appointed organisations rather than individuals.
The new composition of the JTPF also includes non-governmental institutions alongside multinational
enterprises, Professional Services Firms, industry organisations and government representatives of each
Member State.
The Network of PwC Member Firms, appointed as one of only 18 non-government organisations, will be
represented by Isabel Verlinden (Appointed) and Ionut Simion (Alternative). Isabel Verlinden has
previously served as a Member of the JTPF for many years in a private capacity with Ionut Simion’s
assistance throughout those years.
In detail
On May 12, the DirectorGeneral for Taxation and
Customs Union appointed the
Members and the Chairperson
of the Joint Transfer Pricing
Forum (JTPF) for the next two
year mandate starting on 1 April
2015.
The JTPF assists and advises
the European Commission (the
Commission) on transfer pricing
tax matters. Since its set-up in
2002, the JTPF proposes nonlegislative solutions to practical
problems posed by transfer
pricing practices in the EU.
This expert group on transfer
pricing operates on a basis of
consensus and works within the
framework of the OECD
Transfer Pricing Guidelines. The
JTPF focuses on two main
areas: the Arbitration
Convention (a specific dispute
resolution mechanism for
transfer pricing cases) and other
transfer pricing issues identified
by the JTPF and included in its
work programme.
Convention, best practices in
the context of Advance Pricing
Arrangements and its work on
“low value adding intra-group
services” which formed the basis
of the OECD’s discussion draft
on the same topic in the
framework of the Base Erosion
and Profit Shifting Action Plan
(Action Point 10 - Discussion
Draft on Low Value-Adding
Intra-Group Services issued in
November 2014).
Examples of its achievements
include the standardisation of
EU Transfer Pricing
documentation, the Monitoring
of the EU Arbitration
Every EU Member State is
represented whereas candidate
Member States can be invited as
observers. The JTPF has one
representative from each
www.pwc.com
Tax Policy Bulletin
Member State’s tax administration
and the Commission also appoints 18
non-government organisation
members. It is chaired by an
independent chairperson.
For the first time in its history, the
Commission has appointed
organisations rather than individuals.
In their application to the
Commission, organisations were
requested to appoint a credentialed
transfer pricing expert to represent
the organisation, and also an
alternate, where needed or
appropriate.
The Network of PwC Member Firms
was appointed as one of the 18 nongovernment organisation members of
the JTPF and is honoured to
2
meaningfully contribute to the JTPF
through its global network of transfer
pricing professionals and to continue
its efforts to find workable solutions
for all stakeholders within the arm’s
length principle.
The takeaway
It will be represented by Isabel
Verlinden, PwC’s Global Head of
Transfer Pricing. Ionut Simion, PwC’s
newly appointed Territory Senior
Partner in Romania and CEE Transfer
Pricing Leader will serve as her
alternative.
Of particular interest is the somewhat
more diverse composition of the
JTPF’s non-government members. In
addition to multinational enterprises,
Professional Service Firms and
industry organisations, nongovernmental institutions now also
have a seat at the table.
Isabel has been a Member of the JTPF
in a personal capacity for many years
whereas Ionut has assisted her
throughout this term.
The first meeting of the newly
mandated JTPF will be on 25 June
2015.
The Members and the Chairperson of
the EU Joint Transfer Pricing Forum
(JTPF) have been appointed for a two
year mandate.
The list of organisations appointed as
members of the JTPF is as follows:
Name of the organisation
Appointed representative
Alternative
BDI (Federation of German Industries)
Kaiser, Philipp
Stoltenberg, Julia
BEPS Monitoring Group
Picciotto, Solomon
Hji Panayi, Christiana
Brose Fahrzeugteile GmbH & Co KG
Menninger, Jutta
CMS Bureau Francis Lefebvre
Gilbert, Bruno
Deloitte
Georgijew, Iwona
Morris, Edward
EATLP
(European Association of Tax Law Professors)
Martín Jiménez, Adolfo
Kofler, Georg
Eurodad
Ryding Tove, Maria
Hallun, Christian
Financial Transparency Coalition
Roovers, Koen
Cobham, Alex
Grant Thornton
Dali-Ali, Chaid
Nicholls, Wendy
International Tax Center Leiden
(Transfer Pricing Research Center)
Simontacchi, Stefano
A.P. Moller Maersk
van der Torre, Mark-Jan
NERA Economic Consulting
Llinares, Emmanuel
Plansee Group
Baumgartner, Brigitte
Prysmian Group
Beretta, Laura
De Robertis, Gianni
PwC Network of Member Firms
Verlinden, Isabel
Simion, Ionut
Repsol Group
Bermúdez, Rocío
Bokobo, Susana
TPCA
(Transfer Pricing Center Association –
Stowarzyszene Centrum Cen Transferowych)
Rzymkowska, Sylwia
AB Volvo
Barenfeld, Jesper
Gonnet, Sébastien
pwc
Tax Policy Bulletin
Let’s talk
For more information, please contact:
Transfer Pricing
Isabel Verlinden, Brussels
+32 2 710 44 22
[email protected]
Ionut Simion, Bucharest
+40 21 225 3702
[email protected]
Gaby Bes, Amsterdam
+31 8 879 24 144
[email protected]
Jonas Van de Gucht, Brussels
+32 9 268 8336
[email protected]
Global Tax Policy
Stef van Weeghel, Amsterdam
+31 (0) 8 879 26 763
[email protected]
Stay current and connected. Our timely news insights, periodicals, thought leadership, and webcasts help you
anticipate and adapt in today's evolving business environment. Subscribe or manage your subscriptions at:
pwc.com/us/subscriptions
© 2015 PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved. PwC refers to the United States member firm, and may sometimes refer to
the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details.
SOLICITATION
This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
3
pwc