Main Summit 2026 - Day 1 Agenda (In Development & Subject to Change)Tuesday, February 10, 2026

With the pending OECD discussion draft on the pricing of intercompany services, the panellists will engage in a discussion of services that may fall outside the typical markup on cost remuneration with a supporting CPM analysis, such as high-value-added services or services embedded with high-value intangibles.

Mayra Lucas, Senior Transfer Pricing policy Advisor at the OECD in Paris, will be joining us in person in Florida to brief our audience on key developments at OECD level and lift the veil of what might be on the pipeline beyond 2026. Ms Lucas will also be taking questions form the audience and participate in other key discussion on the agenda not least with reference to Amount B.

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 and how tax administrations from key jurisdictions are responding.

This panel brings together leaders from multinationals to address global uncertainty surrounding OECD’s Pillar 2. With implementation timelines shifting and divergent local rules emerging, companies face unprecedented challenges in aligning global tax strategies and ensuring compliance across jurisdictions. Experts will share practical approaches to mitigate risks, choosing the countries where to report, adapt governance frameworks, and handle scrutiny from external auditors, while keeping an eye on options for potential litigation, based on EU or local tax law, like the UTPR-case, and tax treaties.

This session will discuss how multinationals are responding to the challenges and opportunities presented by evolving trade policies and new regulatory frameworks. With the introduction of OBBBA, alongside the complexities of global tariffs, businesses must reassess their transfer pricing strategies to ensure compliance while maintaining operational efficiency. During this session seasoned in-house transfer pricing experts will share their experiences and strategies for restructuring supply chains, managing intercompany pricing, and addressing the trade and tax implications of these changes. Attendees will gain actionable insights into aligning business structures with new legislative requirements, mitigating risks, and leveraging innovative approaches to thrive in an increasingly complex and uncertain global trade environment.