2009 Ernst & Young Global Transfer Pricing Survey Findings - Tax Authority Insights

Tax departments are under increasing pressure to manage transfer pricing risks with greater precision in more jurisdictions. A rapidly developing regulatory environment, new enforcement tactics and shifting fiscal policies make this ever more complex to achieve. Ernst & Young recently conducted interviews with tax authorities around the world to obtain insights on both common and unique approaches to transfer pricing issues, including use of penalties, scrutinized transactions, audit triggers, documentation and controversy.

You are cordially invited to join a live Thought Center webcast for a panel discussion to learn how to deal with the economic, regulatory and fiscal changes taking place in transfer pricing around the world. Frank Ng of Ernst & Young LLP's Tax Controversy and Risk Management Services group and former United States Internal Revenue Service (IRS) Commissioner of the Large and Mid-Size Business (LMSB) Division, will discuss the IRS approach and attitude toward transfer pricing enforcement, including the IRS' coordination efforts with other tax authorities around the globe.

This 75-minute webcast is designed for Directors of Tax, Directors of International Tax, International Tax and Transfer Pricing Managers, Vice Presidents of Tax and Finance, Chief Financial Officers and Tax Analysts. You will have the opportunity to ask questions through the website and panelists will answer as many of your questions as time permits. Discussion topics will include:

• Critical importance of transfer pricing to MNEs
• Changing transfer pricing approaches and attitudes held by tax authorities around the globe
• Audit experiences
• Key trends in audits, dedicated resources, industry focus, penalties and controversy drawn from interviews in 50 countries
• Economic downturn and focus on transfer pricing as a means of revenue generation
• US perspectives and regulatory changes presented by a former IRS representative

Featured panelists
Dan Karen, Ernst & Young LLP, National Tax - Transfer Pricing, Atlanta
Frank Ng, Ernst & Young LLP, Tax Controversy and Risk Management Services, Washington, D.C.

Moderator
David Canale, Ernst & Young LLP, Director of Transfer Pricing Controversy Services, Washington, D.C.