The Future of the Arm's Length Principle conference

The Future of the Arm’s Length Principle

Wednesday, 29 November 2017, 15:00-18:30

Chancellor’s Hall, Senate House, University of London, Malet St, Bloomsbury, London WC1E 7HU

Significant reforms to the arm’s length principle (ALP) were identified as a major priority for the OECD’s recent BEPS project. In consequence, the BEPS output includes a raft of new transfer pricing measures intended to counter avoidance activity relating to income allocation within a multinational group. BEPS also introduced an increased focus generally on substance and transparency, and, in the process of reform, triggered a material hike in the complexity of applying the ALP.

Against this background, this conference will explore what it means to apply the TP and PE attribution rules in the aftermath of BEPS, and will also consider future directions for reform. The discussion of future options for the ALP will include those areas on which the OECD is planning to focus as well as other areas which are arguably high priorities for reform if the ALP is to remain viable.

The OECD’s new head of transfer pricing, Tomas Balco, will speak about the OECD’s work and priorities. Richard Collier, Associate Fellow of the CBT, will present the conclusions from his new book co-authored with Joe Andrus and published by Oxford University Press, Transfer Pricing and the Arm's Length Principle After BEPS. Other speakers will include Louise Sykes, Head of Transfer Pricing at XL Catlin; Matt Hardy, Tax Director for Africa and Asia at Diageo; and Michael Devereux, Director of the CBT.

Conference registration will open at 15:00. The conference itself will begin at 15.30 and will be followed by drinks at 17.30.

The finalised programme will be available on our website shortly.

The event is free to attend.