ROUND TABLE: International taxation and transfer pricing - Overview of current state of transfer pricing in Latin America Notable recent developments Highlights of comparative analysis of transfer pricing regulations in Latin America Strategic Transfer Pricing in Latin America: building solid positions for royalties and services charges Peter Meenan, Deloitte Tax, LLP, Atlanta, Georgia, U.S.A. Iván Gutiérez Lombardo, Deloitte Tax, Miami, Florida, U.S.A. Peter Meenan Transfer Pricing Principal at Deloitte Tax LLP Location : Greater Atlanta Area Graduate of Purdue University - Krannert School of Management http://www.linkedin.com/profile/view?id=31517664&authType=NAME_SEARCH&authToken=1wq4& locale=en_US&srchid=1444279441391622148852&srchindex=4&srchtotal=13&trk=vsrp_people_res_n ame&trkInfo=VSRPsearchId%3A1444279441391622148852%2CVSRPtargetId%3A31517664%2CVS RPcmpt%3Aprimary - background-education Experience Principal / Leader Southeast Transfer Pricing, Deloitte Tax LLP May 2008 – Present (5 years 10 months)Atlanta, GA USA Senior Partner and Economist in Deloitte Tax's Southeast transfer pricing practice, working with a team of over 50 transfer pricing and international tax specialists. Our transfer pricing practice covers all facets of the transfer pricing - planning, audit defence, documentation, APAs, etc. Deloitte Tax transfer pricing leader in the Media and Telecom sectors - voted by Euromoney as a World's Leading Transfer Pricing Adviser, 2012, 2010, etc. - voted by Legal Media Group as a World's Leading Tax Adviser, 2011, 2009, etc Transfer Pricing Partner, Deloitte Japan (Tohmatsu Tax Co.) April 2004 – May 2008 (4 years 2 months)Tokyo, Japan Seconded from Deloitte Tax to Deloitte Japan. Partner and Senior Economist in Deloitte Tokyo's transfer pricing practice, serving clients in Japan and In Asia on transfer pricing matters. Co-managed Deloitte's Tokyo transfer pricing practice, which had over 50 full-time transfer pricing specialists. Succesfully concluded transfer pricing audit defense engagements, due diligence, intangible property planning, advanced pricing agreements. Trained tax authorities in Malaysia and Vietnam - Developed and lead Deloitte's Asian transfer pricing training for partners, managers, and staff. Transfer Pricing Partner, Deloitte Germany GmbH June 2000 – May 2004 (4 years)Duesseldorf, Germany Seconded from Deloitte Tax to Deloitte Germany. Partner and Senior European Economist in Deloitte Germany's Transfer Pricing Group. Co-developed and co-managed Deloitte Germany's transfer pricing group, including hiring, training, and leading a team the surpassed 30 transfer pricing specialists during my tenure. Developed a significant book of business of German, European, U.S. and Asian transfer pricing business. Developed and lead Deloitte's European transfer pricing training at the partner/manager and staff levels. Director/Principal Manager, Deloitte & Touche UK June 1997 – May 2000 (3 years)London, United Kingdom Seconded from Deloitte Tax to Deloitte UK. Peter lead a JV comprising five Deloitte firms (US, UK, Belgium, Germany, Netherlands) with a primary responsibility to develop and grow Deloitte's European transfer pricing practices in cooperation with Deloitte's European transfer pricing leaders. Main areas of responsibility included sales generation, marketing, proposal and scope development. As a member of Deloitte's European Transfer Pricing Management Committee, Peter also had a responsibility for developing Deloitte's strategic marketing plan and hiring and training Deloitte European transfer pricing specialists. Senior Manager, Deloitte Tax LLP October 1993 – May 1997 (3 years 8 months)New York, NY USA -Promoted from Senior to Senior Manager in four years. -Served a large variety of clients in many industries in engagements that included planning, documentation, audit defense, and mutual agreement procedures. - Spoke extensively at transfer pricing seminars, including seminars in Tokyo, Japan and Paris, France. Assistant Professor Economics, Loyola College in Maryland September 1989 – September 1993 (4 years 1 month)Baltimore, MD Lectured in the Executive MBA, MBA, and undergrad schools. Taught managerial economics, microeconomics, and production management. Research concentrated in the are of property rights and contracts, law and economics. Ivan S. Gutierrez Lombardo Senior Manager Transfer Pricing Deloitte Tax LLP Miami, FL igutierrez@deloitte.com Ivan is a Senior Manager of Deloitte Tax LLP with 14 years of transfer pricing experience. Ivan worked with Latin American leadership establishing transfer pricing practices throughout the region working on numerous local and global transfer pricing projects including documentation and planning projects and coordinating regional documentation and planning projects. In 2006, Ivan joined our office in Hong Kong for two years assisting companies with tax transfer pricing planning, documentation, and other conflict resolution matters with respect to HK, China, and various Asian countries. Ivan has been with Deloitte Tax U.S. Transfer Pricing team since 2008 and has been involved in projects including analysis of intangibles and cost sharing, Advanced Pricing Agreements, and analysis of complex financial transactions. Ivan has authored and coauthored articles on transfer pricing including the final chapter in the 2006 Latin America supplement of the International Tax Review and various other publications. Ivan holds a bachelors degree in Management and a masters degree in Finance.