Main Summit 2026 - Day 2 Agenda (In Development & Subject to Change)Wednesday, February 11, 2026

Join us for a dynamic session focusing on the latest information and trends across the Americas, EMEA, and APAC. Our experts will unpack recent developments, offering insights into how these changes affect your transfer pricing landscape. You'll gain a deeper understanding of emerging trends and learn how to adapt your region strategies effectively. This session is perfect for those looking to stay informed and ahead of global transfer pricing developments.

The objective of this session is to explore developments in the valuation of intangible assets, focused on how multinational groups are successfully adapting their IP strategies in todays evolving tax and business environment. Specifically we will address how practitioners are evolving their methodologies for valuing intangibles considering the increasing role of data and digital assets in driving value, recent controversy trends and court cases, changes to workforce and DEMPE considerations, and changes to US regulations, among others.

This panel will explore how global mobility, evolving profit allocation models, and permanent establishment (PE) risks intersect in modern transfer pricing and tax administration. Panelists will provide perspectives on the rising use of “tax-only” adjustments that diverge from operational reality, highlighting challenges in aligning legal structures, substance, and future governance frameworks. The session will provide practical insights on managing documentation, defending positions under increased audit scrutiny, and designing governance models that anticipate cross-border mobility and PE exposure in administrable ways.