2025 Agenda - Main Summit Day 1Tuesday, 18 February 2025

Transactions involving intangibles are often regarded as carrying a high risk of tax challenge. Yet DEMPE analysis is often superficial and confused, and many MNEs fail to design and implement transactions which are commercially rational and make sense legally. The result is that the MNEs are exposed to unnecessary TP risks, and their ability to protect and enforce IP rights is compromised. This briefing will explain common misconceptions regarding DEMPE, and will provide attendees with a practical overview of the sequence of steps needed to design transactions which have legal substance.

In keeping with previous stagings of our opening panel session, dedicated to the discussion and analysis of the most salient TP policy developments around the globe, we have once again assembled a distinguished group of officials to share critical insights on ongoing policies as well as future ones in the works. Following on from Mayra Lucas’ keynote, the panel will pick up on some of the themes raised in her opening speech, not least with reference to the OECD work on the Pillars. Delegates will also hear about the current work of the U.N. and its role in establishing a framework convention on international tax cooperation, that will help shape tax reform globally in the coming years.

This session will bring together senior tax officials from various jurisdictions with a wide range of international tax experience. As well as covering issues and questions arising from the topics indicated below they will also seek to address themes and concerns that may arise until the date of the conference. Key discussion points for 2025 include:

• Trends and stats in relation to MAP and APA
• Implementation status for Pillar 2, Amount B and Amount A
• MAP outcomes and consequences if not accepted

Pillar 2 is one of the most significant changes to the international tax landscape in decades. A global minimum tax of 15% and introduction of tax accounting concepts into tax law for the purposes of considering effective tax rates represents a fundamental shift in the way businesses are taxed. The additional global compliance and reporting obligations are significant, placing increased demands for data, on finance teams and IT systems. Many countries have now adopted Pillar 2 into domestic legislation, with the multinational and domestic top up tax rules already in effect. This panel, assembling Pillar 2 Leads in their organizations, will discuss practical suggestions on how to approach Pillar 2 and successfully address key “pain points” ahead of filling deadlines.

The OECD’s report on Amount B of Pillar One does not yet provide the certainty companies and countries seek for approaching the transfer pricing of baseline wholesale marketing and distribution activities. Considerable effort has been invested in developing the Amount B framework. If implemented in a manner that does not compromise the arm’s length principle it is likely to be well received by both taxpayers and tax administrations. The report has however created too many forks in the road for tax administrations to choose from, ranging from whether to adopt or reject the guidance, to introducing a more qualitative scoping criterion. In the short term more taxpayer and tax administration resources may be required to wade through the Amount B requirements and result in an unwanted spike of disputes. The panel will discuss the Amount B report, whether the goal of introducing a simplified and streamlined approach has been achieved and the wider implications of the proposed framework.

Companies with complex global supply chains are facing an increasingly challenging regulatory environment that puts significant pressure on tax departments to deliver simultaneously on risk management, proliferating global reporting requirements, and changing in tax/transfer pricing regulations all whilst playing an increasingly strategic role for their organizations. Our panel will explore best practices and ideas for tax functions that are looking to allocate their resources to respond successfully to this rapidly evolving global tax and transfer pricing landscape including assessing technology available to assist with the transfer pricing function. Specific areas of discussion will include Data management, Transfer Pricing Automation and Implementation, Global Documentation strategies, CbC reporting/Pillar 2, and analytical tools for strategic planning. The panel will also explore best practices and lessons learned from integration with Finance and Operations and how to overcome challenges with this key area of cross-functional collaboration.

This panel brings together large taxpayers, tax Authorities and specialist advisors to shed light on how will AI is currently being used and how it might further be deployed by Revenue authorities in the future. Will it result in the emergence of fairer tax systems for both fiscs and multinational taxpayers? This session will explore the scope of AI in transfer pricing, discuss potential abuse and protection mechanisms, and how Artificial Intelligence can be used to foster fairer taxation frameworks globally, as well as greater cooperation between Taxpayers and Tax Administrations.