Main Summit Day 1 - 2024Tuesday, 18 June 2024

Mayra Lucas, Senior Transfer Pricing Advisor at the OECD, is currently working on the OECD project on the tax challenges arising from the digitalisation of the economy, focusing on Pillar 1 and leading the work on the 2020 review of the CbC minimum standard. She will be joining us again in London to brief you on key developments pertaining to Amount B, while also lifting the veil on what else might be on the OECD pipeline. Don’t miss this opportunity to put your questions directly to Mayra on the day or send these in advance to michele.costa@informa.com

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. Another key area of focus for the discussion will be the European Commission’s Transfer Pricing Directive. This has received considerable attention since its unveiling and we will benefit from Mauro Faggion’s technical knowledge of its objectives and reach, so our audience can get in-depth understanding of the practical issues at play for multinationals in scope. Last but not least, we will hear from Hector Thompson of the ATO, who will help us understand how Tax Administrations are keeping up to speed with global tax policy reform vis-à-vis the challenges of their domestic fiscal landscapes. As always, the audience will be encouraged to send their questions through via Slido.

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.

The format:
Our brand-new series of quick-fire and thought-provoking 15 minutes presentations by leading industry speakers was conceptualised to inspire and respond to the many requests we receive for more corporate-led presentations to complement our panels format. Short enough to keep you interested. Interesting enough to spark the debate. Not to be missed.

The content:
Kari will look into today’s complex and disintegrating tax policy landscape and provide commentary as to the potential future implications for MNEs. Some latest controversy developments will also be highlighted.

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. The panel will discuss practical suggestions on how to approach Pillar 2 “from the trenches”.

The format:
Our brand-new series of quick-fire and thought-provoking 15 minutes presentations by leading industry speakers was conceptualised to inspire and respond to the many requests we receive for more corporate-led presentations to complement our panels format. Short enough to keep you interested. Interesting enough to spark the debate. Not to be missed.

The content:
Lukasz will consider the practicalities of taking global tax policy from blueprint to execution. Points under consideration include:
• “Supply” of tax experts vs. “demand” in new policy landscape – will market dry?
• Taxpayer vs. tax administration competition on the labor market
• Demography trends require us being more productive – also in tax?
• Does increase in compliance costs results with positive ROI for tax revenue?

The role of economic expertise in transfer pricing is of ever increasing importance given the need for precise analysis in the context of disputes, enquiries, arbitration and litigation. Furthermore many tax authorities now have dedicated teams of economists who are able to challenge comparable data with greater levels of scrutiny into transfer pricing analyses. To address these disputes properly, expertise and insights from both transfer pricing and economic consultancy practices can be invaluable, and indeed are now normal practice in arbitration and litigation. Therefore, the application of economics-based techniques may be necessary to tackle more difficult issues (such as complex financing instruments) and provide expert opinions in arbitration and litigation. This talk will explore what the benefits are of using more sophisticated economic methodologies for answering transfer pricing questions, and the importance of objectivity and independence for transfer pricing valuations and valuation standards within economic analyses.

Join Graham Richter of EY UK’s Tax Technology & Transformation practice and a group of distinguished TP experts to discuss how the combination of GenAI and “traditional AI” is revolutionizing Transfer Pricing related work by automating complex, labour-intensive and time-consuming processes that require understanding and analysis of both numerical/financial data as well as large volumes of text, images, audio and video files, delivering faster and more accurate outcomes. Our panellists will highlight practical applications that support TP professionals with demanding tasks, showcasing examples that significantly improve operational efficiency and strategic decision-making in Transfer Pricing. We will also explore how tax administrations are deploying AI technology to conduct more effective audits and enquiries.

ESG is fast becoming the most important issue on Board agendas, so how does tax, and more specifically, transfer pricing play a role? In this session, we will explore both the technical and practical ways in which ESG impacts transfer pricing and Group value chains, looking at changing business models and implications across the TP lifecycle. The panel will also consider how TP professionals should approach this issue with the wider business as well as external stakeholders.

The format:
Our brand-new series of quick-fire and thought-provoking 15 minutes presentations by leading industry speakers was conceptualised to inspire and respond to the many requests we receive for more corporate-led presentations to complement our panels format. Short enough to keep you interested. Interesting enough to spark the debate. Not to be missed.

The content:
Karine Halimi-Guez of Booking.com will take to the stage with a thought-provoking session that asks you to reconsider the concept of “tax expert”. We won’t say more!

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