2023 Agenda (Main Summit Day 2)

In-house tax leaders share a platform with tax administrations. Together, they will share their advice and experiences in successfully engaging, communicating and cooperating with a view to fostering sustainable compliance. Tax directors share best practice advice on how to engage with tax authorities with a view to increasing awareness of their business structures and tax planning strategies resulting in a satisfactory level of cooperative compliance for both parties. Speakers will offer their thoughts on the do’s and don’ts in establishing a relationship of mutual trust with a tax administration.

Several international transfer pricing court cases will be discussed where the speaker will address whether the taxpayer submitted (contemporaneous) transfer pricing documentation, which of the parties had (was deemed to have) the burden of proof, what the most important arguments of the parties were including the evidence brought forward and what the most important considerations of the Courts were in reaching their conclusions. Based hereon, several recommendations will be made how taxpayers can strengthen their position.

This panel will explore the global landscape of transfer pricing controversy, including recent court decisions, current developments, and trends in transfer pricing enforcement. The panel will discuss emerging themes in transfer pricing controversy that may lead to disputes in the horizon and possible avenues for preventing or resolving those disputes.

APAs and MAPs continue to remain the most important approaches to preventing TP disputes and providing relief from double taxation when they do occur. Join our diverse panel as we dive into the latest trends regarding APAs and MAPs, highlighting practical strategies and best practices. We aim to bring anecdotal insights based on interactions with tax authorities across the globe as businesses endeavour to manage their transfer pricing positions and mitigate the risk of double taxation.

With the introduction of the Chapter X in the OECD Guidelines 2022 and the increasing base rates in the global market, transfer pricing specialists are facing more challenges when pricing financial transactions. In this session we will cover this topic in some detail including:

• What are the key challenges for transfer pricing specialists in the past year and what are the pragmatic solution options available?
• Is there any trend/common theme in tax/transfer pricing audits on financial transactions by tax authorities around the world?
• What are the practical measures for taxpayers to take in order to manage transfer pricing risks arising from intercompany financial transactions?