Latest Agenda 2025 (Subject to Change)Thursday, 6 November 2025

International policy makers and tax authorities come together to brief delegates on the latest tax policy developments driving the global tax transparency agenda and the impact this may have on the tax controversy and dispute resolution landscape. This is a valuable opportunity to learn about the latest OECD and EU measures on improving tax transparency as well as about the latest approaches by tax administrations to the litigation of complex tax disputes following a number of key high-profile decisions by the Tax Courts.

Is tax avoidance inherently wrong? If so, what distinguishes it from part of all of us naturally navigate everyday life decisions? If unacceptable taxpayer behaviour is fundamentally the same as other human behaviour, what is it that makes some things unacceptable and others not? And has that boundary shifted? This session explores the dilemma of “unacceptable” versus “acceptable” in a world where businesses fight hard to minimise every cost.

The global drive towards tax transparency continues to top the agendas of the OECD (see CbCR), the EU Commission (see DAC6/DAC7), tax authorities, multinationals, and even institutional investors attuned to ESG requirements. Corporations' cross-border tax arrangements remain therefore under intense scrutiny, and the introduction of mandatory global tax information disclosures will guarantee that the drive for transparency continues to be at the core of a responsible tax function. But with greater transparency comes greater risk. This panel will help identify emerging risks associated with public disclosures, consider adequate strategies to satisfy the information needs of tax authorities, and take a look at the role of data management systems in the operationalisation of key transparency requirements.

Ten years after first being mentioned by the OECD, the concept of attributing profits to DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) Functions remains at the heart of an increasing number of tax disputes. This panel session including corporates, advisors and tax administrations will reflect on the evolution of DEMPE and how to deal with what comes next. They will provide their perspectives and experiences with DEMPE-related disputes, including typical situations that can give rise to disputes, strategies to deal with these and typical pitfalls of DEMPE arguments.

This presentation will discuss best practices and practical approaches to handle transfer pricing cases in anticipation of litigation. We will discuss roles of solicitors and barristers, when to rely on existing documentation or involve outside experts, privilege concerns, and how to have a defence ready in anticipation of litigation. We’ll draw experience from cases tried in the U.S., Ireland, and Australia.

Most might say that fairness in tax is about applying the right rules to the right facts, but what about when these facts are hard to discern and even harder to prove? This panel examines the messy realities of the evidence tax law can demand and when taxpayers, HMRC and the tribunal alike should know enough to be able to make an informed decision.

In today's volatile geopolitical landscape, tax professionals face unprecedented challenges navigating the complex interplay between key areas of uncertainty such as with Pillar Two implementation, and escalating trade tensions. The uncertainty surrounding global minimum tax rules coincides with a concerning rise in retaliatory tariffs and "revenge taxes" that distort international trade flows and alter competitive advantages in key markets. This high-stakes environment demands sophisticated risk management strategies as multinational enterprises contend with potential double taxation, compliance burdens, and the ripple effects of trade policy becoming a geopolitical weapon. The resulting uncertainty damages investor confidence while creating new controversy risks that demand proactive management. Join us for critical insights into what businesses are doing to respond to this complex risk landscape.

Given the restrictions imposed on the European Union through the principle of legislative conferral and the partial regulatory autonomy of Member States in the field of taxation, the control of illegal state aid remains the primary area of intervention in national tax policies. Following a short briefing on the latest State Aid by the European Commission, this panel will discuss how the Commission has applied its guiding principles; recent ECJ decisions and what extent the ECJ has accepted the Commission’s application; and what we can expect in the future with the pending case and EU initiatives, taking also into account the need for the EU to remain competitive in today's turbulent global market.