Main Summit 2025 - Day 1

The Pillar 2 project has so far been viewed as one of the most significant reforms to the international tax landscape in decades, but how will implementation be impacted by the U.S.'s current stance? A global minimum tax of 15% and introduction of tax accounting concepts into tax law for the purposes of considering effective tax rates would represent a fundamental shift in the way businesses are taxed. On the ground, heavy global compliance and reporting obligations continue to place increased demands for data on finance teams and IT systems, and 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 organisations, will discuss implementation status within their businesses or jurisdictions, and analise how the U.S. position, as well as responses from the OECD and EU, might shape the project going forward.

In the fireside chat, Batanayi Katongera (Glencore) will talk about challenges and opportunities for international tax cooperation with Ilka Ritter (United Nations). The discussion will focus on how global tax governance has evolved over time alongside changes in the real economy and will delve into the current state of play of the negotiations of the United Nations Framework Convention on International Tax Cooperation and what a new membership of the UN Tax Committee. The conversation will also consider the practical implications for multinational enterprises, including how shifting international norms may influence transfer pricing policies and tax risk management strategies.

The session will cover US tax developments that are expected to be introduced in the first half of 2025. This will include specific regulations in the IRC that will be extended or modified as well any new regulations, proposed or existing, that will affect businesses in the US and internationally. Additionally, we will review the new administration’s position on non-US tax agreements, such as the OECD’s BEPS initiative, as well as local country tax initiatives, such as DSTs, and how the US might respond.

In this short demo and presentation, Alexandra Trotta, Head of OTP Consulting (U.S.) at EXA AG, will guide attendees through "Managing Operational TP for Tangible Goods and Services: One-Stop Shop for Comprehensive Intercompany Management". Don't miss this opportunity to gain critical insights into this critical area of TP for in-house professionals and advisors alike.

Join our expert panel as we examine the transfer pricing challenges 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 TP risks, maintaining compliance with local tax authorities, and aligning mobility strategies with OECD guidance, including anticipated updates on this critical issue.

This panel will explore the transformative impact of Generative AI, Machine Learning, and other technological disruptors on transfer pricing. Our expert speakers will discuss how these innovations are enhancing TP policies, data analysis, risk assessment, compliance strategies, and interactions with tax authorities. We will examine how AI can streamline aspects of functional analyses, improve benchmarking accuracy, and support intangible asset valuation - while also addressing its limitations and regulatory challenges. Panellists will share real-world applications, benefits, and risks of integrating AI into transfer pricing processes in an evolving global tax landscape.

This panel comes together to discuss tax transformation and digitalisation. The discussion will focus on people and processes as much as the technological transformation underpinning the rapid evolution of the tax function. The topics to be discussed include:

• Dealing with the increased burden of tax administration
• Increasing transparency and improving the efficiency of tax operations
• Designing and implementing a successful tax technology strategy; and
• Solving data issues hindering the consistency of the tax compliance processes