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Transfer Pricing Controversy Chronicles: KPMG Insights

CPE 1.0

Webcast

Webcast overview

Is your company facing audits or other tax controversies around the globe? Would you like to hear about how other multinationals have navigated these complex issues as tax authorities continue to take strong stances? 

KPMG LLP (KPMG) is pleased to invite you to a one-hour TaxWatch Webcast that highlights the global tax controversies faced by multinational companies.

Senior transfer pricing dispute resolution professionals from KPMG member firms in the U.S., Canada, Denmark, Netherlands, and Switzerland will discuss real-life experiences they’ve faced with their clients including the following:

  • Transfer pricing audit in the Netherlands focused on a “business” transfer over 15 years ago
  • Disallowed management fees for foreign head office in Canada
  • A new government-to-government tool developed for US-India APAs
  • Allocation of a significant portion of a multinational company’s profits to its Swiss principal company
  • Deemed transfer of intangibles in Denmark
  • U.S. IRS nudge letter received by a company following several years of sustained losses

Meet our webcast team

Image of Cameron Taheri
Cameron Taheri
Principal, Tax - Co-Lead WNT, Tax Controversy & Dispute Resolution, KPMG US
Read bio
Image of Jenna Wilkinson
Jenna Wilkinson
Senior Manager, Tax - Economic and Valuation Services, KPMG LLP
Image of Rui Che
Rui Che
Managing Director, Tax, Economic & Valuation Services, KPMG US
Read bio
Image of Rune Meldgaard Christensen
Rune Meldgaard Christensen
Director, Tax, KPMG Acor Tax
Read bio
Image of Rune Meldgaard Christensen

Rune Meldgaard Christensen

Director, Tax, KPMG Acor Tax

Rune is a distinguished Tax Director with KPMG Acor Tax in Denmark, specializing in transfer pricing within KPMG’s Global Transfer Pricing Services. With extensive expertise in transfer pricing litigation, tax controversy, and dispute resolution, Rune has a proven track record of success. His notable career includes serving as the Danish Government's lead lawyer in several of Denmark's most significant and intricate tax and transfer pricing cases. Rune's transition to KPMG Acor Tax brings unparalleled insights into tax authority strategies, significantly bolstering the firm's leadership in transfer pricing disputes and litigation. His deep understanding of both governmental and private sector perspectives uniquely positions KPMG Acor Tax at the forefront of the industry, ensuring clients receive top-tier representation and strategic guidance in navigating complex tax challenges.
Image of Craig Reeder
Craig Reeder
Partner, Tax, KPMG LLP
Read bio
Image of Agata Uceda
Agata Uceda
Partner, Transfer Pricing, KPMG
Read bio
Image of Raffaele Farigu
Raffaele Farigu
Manager, Tax – Transfer Pricing, KPMG AG
Read bio
Image of Raffaele Farigu

Raffaele Farigu

Manager, Tax – Transfer Pricing, KPMG AG

Raffaele is a Manager with the transfer pricing team of KPMG Switzerland based in Zurich. He has more than 6 years of international cross-border tax experience working with major multinational companies on transfer pricing, and value chain management projects.

Raffaele has supported clients on several transfer pricing matter, particularly focusing on set-ups of new companies and transfer pricing policies, business model conversions and restructurings, review and strengthening substance in regional and global headquarter locations. He has been involved in several TP tax audits and controversies for Swiss headquartered multinational corporations, as well as in negotiations of advance pricing agreements (“APAs”). He holds an integrated bachelor and master degree in law at University of Cagliari, Italy.
Image of Cameron Taheri
Cameron Taheri
Principal, Tax - Co-Lead WNT, Tax Controversy & Dispute Resolution, KPMG US
Read bio
Image of Jenna Wilkinson
Jenna Wilkinson
Senior Manager, Tax - Economic and Valuation Services, KPMG LLP
Image of Rui Che
Rui Che
Managing Director, Tax, Economic & Valuation Services, KPMG US
Read bio
Image of Rune Meldgaard Christensen
Rune Meldgaard Christensen
Director, Tax, KPMG Acor Tax
Read bio
Image of Rune Meldgaard Christensen

Rune Meldgaard Christensen

Director, Tax, KPMG Acor Tax

Rune is a distinguished Tax Director with KPMG Acor Tax in Denmark, specializing in transfer pricing within KPMG’s Global Transfer Pricing Services. With extensive expertise in transfer pricing litigation, tax controversy, and dispute resolution, Rune has a proven track record of success. His notable career includes serving as the Danish Government's lead lawyer in several of Denmark's most significant and intricate tax and transfer pricing cases. Rune's transition to KPMG Acor Tax brings unparalleled insights into tax authority strategies, significantly bolstering the firm's leadership in transfer pricing disputes and litigation. His deep understanding of both governmental and private sector perspectives uniquely positions KPMG Acor Tax at the forefront of the industry, ensuring clients receive top-tier representation and strategic guidance in navigating complex tax challenges.
Image of Craig Reeder
Craig Reeder
Partner, Tax, KPMG LLP
Read bio
Image of Agata Uceda
Agata Uceda
Partner, Transfer Pricing, KPMG
Read bio
Image of Raffaele Farigu
Raffaele Farigu
Manager, Tax – Transfer Pricing, KPMG AG
Read bio
Image of Raffaele Farigu

Raffaele Farigu

Manager, Tax – Transfer Pricing, KPMG AG

Raffaele is a Manager with the transfer pricing team of KPMG Switzerland based in Zurich. He has more than 6 years of international cross-border tax experience working with major multinational companies on transfer pricing, and value chain management projects.

Raffaele has supported clients on several transfer pricing matter, particularly focusing on set-ups of new companies and transfer pricing policies, business model conversions and restructurings, review and strengthening substance in regional and global headquarter locations. He has been involved in several TP tax audits and controversies for Swiss headquartered multinational corporations, as well as in negotiations of advance pricing agreements (“APAs”). He holds an integrated bachelor and master degree in law at University of Cagliari, Italy.

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Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

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