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The 2016 OECD International Tax Conference:OECD-U.S. Business Dialogue on International TaxWashington, DC June 6-7, 2016The Four Seasons Hotel2800 Pennsylvania Ave., NWDraft Agenda – May 12, 2016Conference Day One – June 61:00 – 1:30REGISTRATIONI.1:30 – 2:00Welcome Peter Robinson, President & CEO, USCIB Pascal Saint-Amans, Director of OECD Centre for Tax Policy andAdministrationII.2:00 – 3:15Tax, Trade and InvestmentRemoving tax barriers to cross-border trade and investment is at the core ofthe OECD’s tax work. Tax policies can make growth more sustainable andinclusive by strengthening and expanding opportunities to participate in theeconomy and by sharing the tax burden in a fair manner. The effects ofcollective actions on BEPS and automatic exchange of informationaddressing both tax avoidance and evasion will shape future tax policy forinclusive growth. Tax uncertainty is often cited as a significant impediment todomestic investment as well as cross-border trade and investment. Taxuncertainty in some cases can have larger economic effects on businessdecisions than the amount of direct tax liability. National tax systems in aglobal economy require internationally coordinated rules to avoid doubletaxation, double non-taxation, and harmful tax practices. This panel willdiscuss both how tax policy and tax administration domestically andinternationally can reduce tax uncertainty. Pascal Saint-Amans, Director of OECD Centre for Tax Policy andAdministrationRobert B. Stack, Deputy Assistant Secretary for International TaxAffairs, U.S. TreasuryWill Morris, Chairman, BIAC Committee on Taxation and FiscalAffairs; Director, Global Tax Policy, GE International Inc. (UnitedKingdom)Marty Sullivan, Chief Economist and Contributing Editor, Tax AnalystsPam Olson, U.S. Deputy Tax Leader & Washington National TaxServices Leader, PricewaterhouseCoopers LLP

3:15 – 3:35REFRESHMENT BREAKIII.3:35 – 4:35The BEPS Project: Implementation Challenges and OpportunitiesG20 Leaders in Antalya called on the OECD to develop an inclusiveframework for the implementation phase of the BEPS project so that allinterested countries and jurisdictions that have committed to the BEPSpackage can participate in the work on an equal footing with OECD and G20countries. The inclusive framework will provide an opportunity for developingcountries to take an even more active role in the BEPS work. At the sametime, they face different challenges from more developed countries. Thispanel will discuss the inclusive framework as well as efforts being made tosupport developing countries such as the OECD/UN Tax Inspectors WithoutBorders initiative and the work on toolkits on transfer pricing comparability,indirect transfer of assets, transfer pricing documentation, tax treatynegotiations, base eroding payments, and BEPS risk assessment. IV.4:35 – 6:00Dispute Resolution: Making MAP WorkAction 14 of the BEPS Action Plan recognized that making dispute resolutionmore effective is crucial for the successful implementation ofrecommendations of the BEPS project. Effective treaty dispute resolution isone of the four “minimum” standards resulting from the BEPS project. Thissession will examine the progress made in establishing a robust peer reviewmechanism in the Forum on Tax Administration MAP Forum as well asprogress on mandatory binding arbitration. 6:00 – 7:30Grace Perez-Navarro, Deputy Director, OECD Centre for Tax Policyand AdministrationJames Karanja, Head of joint OECD/UNDP Tax Inspectors WithoutBorders (TIWB) InitiativeRobert B. Stack, Deputy Assistant Secretary for International TaxAffairs, U.S. TreasuryLogan Wort, Executive Secretary, African Tax Administration Forum(ATAF)Janine Juggins, Executive Vice President of Global Tax, UnileverAchim Pross, Head, International Cooperation and Tax AdministrationDivision, OECD Centre for Tax Policy and AdministrationDoug O’Donnell, LB&I Commissioner, IRSMartin Kreienbaum, Director General, International Taxation, FederalMinistry of Finance, GermanyTim McDonald, Vice President - Finance & Accounting, Global Taxes,Proctor & GambleCraig Sharon, Principal, EYRECEPTION

Conference Day Two – June 78:00 – 8:30CONTINENTAL BREAKFASTV.8:30 – 10:00Permanent Establishments: They’re back In 2012, the OECD released for comments a revised version of proposedchanges to the Commentary on Article 5 (the definition of permanentestablishment) of the OECD Model Tax Convention. These proposedchanges dealt with a number of controversial interpretative issues related tothat definition.These changes were put aside, but not forgotten, during the work on Action 7of the BEPS Action Plan. The OECD is currently working on the integration ofthe 2012 proposed changes with the changes made to Article 5 by theReport on Action 7, with a view to producing the new version of Article 5 andits Commentary that will be included in the next update of the Model TaxConvention.The panel will review the main issues that are being dealt with as part of thatconsolidation work. Jacques Sasseville, Head, Tax Treaty Unit, OECD Centre for TaxPolicy and AdministrationQuyen Huynh, Associate International Tax Counsel, U.S. TreasuryPorus Kaka, President, International Fiscal Association (IFA)Manal Corwin, National Leader, International Tax, KPMG10:00 – 10:20REFRESHMENT BREAKVI.10:20 – 12:00Transfer Pricing: Risky Business (Part I)This first session on Transfer Pricing will examine the operation of the riskframework in the revised Chapter I of the OECD Transfer Pricing Guidelines,and will consider its implications for the current work on guidance on theattribution of profits to PEs. The session will also consider how theframework on risk and synergies can inform the work on the transfer pricingaspects of financial transactions. 12:00 – 1:30Andrew Hickman, Head of Transfer Pricing Unit, OECD Centre forTax Policy and AdministrationMike McDonald, Financial Economist, U.S. TreasuryKarine Uzan-Mercie, Vice President, Head of Tax & Vice President,Corporate Initiatives, Coca-Cola EnterprisesPaul Morton, Head of Group Tax, RELX GroupLUNCHEON AND KEYNOTE ADDRESSJohn Koskinen, Commissioner of the Internal Revenue Service

VII.1:30 – 2:30Interest DeductibilityBecause the use of related party interest deductions is one of the easiestways to accomplish BEPS, the Report on Action 4 of the BEPS Action Planestablishes a common approach for countries to take in preventing baseerosion through the use of interest expense and other financial paymentsthat are economically equivalent to interest. This panel will discuss thevarious elements of the common approach and its application. VIII.2:30 – 3:30Achim Pross, Head, International Cooperation and Tax AdministrationDivision, OECD Centre for Tax Policy and AdministrationMike Williams, Director, Business and International Tax, HM TreasuryJason Yen, Attorney Advisor, U.S. TreasurySaul Rosen, Senior Tax Counsel, CitigroupThe Multilateral Instrument: Moving from Policy to RealityThe work on BEPS resulted in a number of agreed changes to the OECDModel Tax Convention. Given that there are more than 3,000 bilateraltreaties in existence, however, implementing these changes through bilateralnegotiation could take years, if not decades. Action 15 of the BEPS ActionPlan called for the development of a multilateral instrument to enablecountries to swiftly amend their tax treaties to implement the treaty-relatedBEPS recommendations. An Ad Hoc Group consisting of 95 countries and anumber of non-State jurisdictions and international organisations was createdfor this purpose, and the development of the multilateral instrument began in2015, with the goal of reaching agreement by the end of 2016.This panel will examine the main issues being addressed by the Ad HocGroup, including 1) the challenge of arriving at a single instrument to modifya widely varied network of existing treaties; 2) how to incorporate flexibilitywhile maintaining clarity and coherence; and 3) how to develop an effectiveprovision on arbitration. Jesse Eggert, Senior Advisor--BEPS, OECD Centre for Tax Policyand AdministrationMike Williams, Director, Business and International Tax, HM TreasuryHenry Louie, Deputy to the International Tax Counsel (Treaty Affairs),U.S. TreasuryMary Bennett, Partner, Baker & McKenzie3:30 – 3:50REFRESHMENT BREAKIX.3:50 – 4:50Transfer Pricing: Risky Business (Part 2)This second transfer pricing session will examine the implications of the riskframework for revised guidance on profit splits. The session will alsoconsider implementation of the approach to Hard-to-Value Intangibles, andthe implications of the revised guidance on cost contributions arrangements. Andrew Hickman, Head of Transfer Pricing Unit, OECD Centre for

4:50 – 5:00Tax Policy and AdministrationBrian Jenn, Attorney Advisor, U.S. TreasuryBill Sample, Vice President – Tax, MicrosoftPhilippe Penelle, Principal, DeloitteClosing Remarks Pascal Saint-Amans, Director of the OECD Centre for Tax Policy &Administration Carol Doran Klein, Vice President and International Tax Counsel,USCIB

Porus Kaka, President, International Fiscal Association (IFA) . attribution of profits to PEs. . 2015, with the goal of reaching agreement by the end of 2016. This panel will examine the main issues being addressed by the Ad Hoc Group, including 1) the challenge of arriving at a single instrument to modify .