julho 09 2020

The Future of the Functional Analysis – Pillar One and Beyond


The OECD/G20 Inclusive Framework on BEPS has reaffirmed its commitment to reach an agreement on a consensus-based two-Pillar solution to address the tax challenges of digitalization by the end of 2020. While the United States’ recent call for a “pause” in the Pillar One discussions draws into question the scope, the timing, and the degree of inclusiveness of any future agreement, there is no doubt that changes to taxation of the digital economy are about to arrive. The changes will, however, depend on whether the moves by tax administrations are multilateral or unilateral, as well as the scope and timing of any agreement. Against this backdrop of uncertainty, this session will address the continued importance of functional analysis in assessing transfer pricing risk in a digital economy.

Learning Objectives

  • Identify transfer pricing issues and the place of digital transactions within global value chains.
  • Learn how to adapt approaches for functional and value chain analysis for the post-digital era, including comparability factors and value drivers such as marketing intangibles and user base.
  • Explore how Pillar One may impact transfer pricing analyses and some ways that functional and value chain analysis can be leveraged and adapted to prepare for both the possible implementation of Pillar One and the challenges likely to arise if Pillar One is not implemented.


  • Kristin Mikolaitis, Nestle USA, Inc.
  • Michael Lebovitz, Mayer Brown
  • Jason Osborn, Mayer Brown
  • Elena Khripounova, Mayer Brown


United States
2:15 p.m. – 3:15 p.m. EDT
1:15 p.m. – 2:15 p.m. CDT
12:15 p.m. – 1:15 p.m. MDT
11:15 a.m. – 12:15 p.m. PDT

7:15 p.m. – 8:15 p.m. BST
8:15 p.m. – 9:15 p.m. CEST

For additional information on the webinar, please contact Shilpa Patel at spatel@mayerbrown.com or +1 312 701 8487.

CPE Information 

Delivery Method: Group Internet Based
Program Level: Overview
Prerequisites: None
Field of Study: Taxes
CPE Credits Available: 1 CPE credit based on a 50-minute hour.

Fees: There is no fee for this webinar. To be awarded CPE credit for this session, you must respond to three out of four polling questions asked during the program.

Cancellation – To cancel your registration, please email Shilpa Patel, spatel@mayerbrown.com.

Tax Executives Institute, Inc. TEI Education Fund is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.NASBARegistry.org.

For questions on CPE certificates, please email meetings@tei.org. Please allow two weeks from the completion of the webinar for certificate delivery before contacting us.

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