Tax Controversy LeadersWednesday, 11 November 2026

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

With cross-border tax disputes becoming ever more likely and increasingly complex, international tax dispute resolution has taken centre stage, becoming a top priority for tax directors and practitioners worldwide. This panel examines the key trends shaping international tax dispute resolution and will explore the choice between international and domestic remedies, including strategic routes, common pitfalls, and timing considerations. The discussion will also address the power (im)balance between taxpayers and tax authorities, covering MAP challenges, the growing use of data, strategic decision-making, and geographical differences. Finally, panellists will contrast the UN and OECD visions for dispute resolution, exploring potential divergence, emerging protocol changes, and lessons learned from BEPS. Attendees will gain practical insight into navigating this evolving landscape.

As tax authorities adopt increasingly sophisticated audit techniques and scrutiny of cross-border transactions intensifies, managing transfer pricing controversy has become a strategic priority for multinational businesses. This panel will explore the evolving controversy landscape, common dispute drivers and key audit risk triggers, alongside practical strategies for strengthening governance, documentation and organisational preparedness. Panellists will examine complex challenges, including exit taxation and price adjustment clauses, as well as the growing role of AI and data analytics in tax audits. The discussion will touch upon actionable best practices for anticipating, managing and resolving transfer pricing disputes.

This session will discuss best practices for using economic experts in the context of tax controversies. Key questions addressed will include identifying when an expert can add value beyond that provided by internal resources or consultants who helped document the as-filed position, common asks of independent experts, maintaining privilege in expert communications, and the steps to take to ensure that a potential testifier’s independence remains uncompromised. The panel will draw on recent examples of effective use of experts in global tax disputes to illustrate these themes.

The first Pillar Two returns are being filed, shifting the focus from implementation and compliance to the next challenge: controversy. Where are disputes most likely to arise, and what happens when multiple jurisdictions take different views? Panellists will discuss practical approaches to identifying, documenting and defending critical positions, managing audit readiness and mitigating dispute risks. Attendees will gain practical insights into managing and mitigating Pillar Two controversy risks.

Join our expert panel as we examine the tax challenges and risks arising from global mobility. We will discuss the implications of the location of senior decision makers on Permanent Establishments (PEs), the allocation of profits, and emerging risks such as remote work taxation and evolving regulatory scrutiny. Our discussion will provide practical insights on mitigating controversy risks, defending positions under increased audit scrutiny, maintaining compliance with local tax authorities, and aligning mobility strategies with the latest OECD guidance on this critical issue.