Main Summit 2026 - Day 1 Agenda (In Development & Subject to Change)Tuesday, 16 June 2026

Saranee de Silva, is a Senior Transfer Pricing Policy Analyst at the OECD, and is currently working on the OECD Global Mobility and TPG Reviews projects. She will be joining us at TP Minds International once again to brief you on key developments pertaining to Amount B, Global Mobility and Intragroup Services, while also lifting the veil on what else might be on the OECD pipeline.

This panel examines key elements of an effective transfer pricing (TP) risk management and defense strategy at a time of geopolitical uncertainty and increased scrutiny. Experts will share their analysis as well as best practices for identifying and mitigating TP risks, and strategies for responding to audits and disputes. Attendees will gain practical insights into building resilient TP frameworks.

This session will discuss how multinationals are responding to the challenges and opportunities presented by evolving trade policies and new regulatory frameworks. With 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 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, mitigating risks, and leveraging innovative approaches to thrive in an increasingly complex and uncertain global trade environment.

This technical session will cover the latest developments in the US and Middle East. Cedric Bernardeau (Head of FTI’s US Transfer Pricing Practice) and Omar Quershi (Head of FTI’s UAE Transfer Pricing Practice) will unpack key transfer pricing and corporate tax considerations for inbound and outbound Middle East operations, alongside the implications of the continued evolution of the US tax and policy landscape for multinational groups.

In light of the fast evolving business environment and OECD’s recent public consultation on their update to Global Mobility (and Article 5 of the Model Tax Convention), Remote Work and Permanent Establishment (PE), this panel will explore how Transfer Pricing challenges intersect with global mobility, remote working, cost and profit allocation models, and PE risks. Our discussion will provide practical insights on mitigating TP risks, maintaining compliance with local tax authorities, and aligning mobility strategies with OECD guidance. 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 to mitigate potential risks.

Explore how Artificial Intelligence is transforming transfer pricing practices, from AI-powered benchmarking tools that select comparables, to automation in documentation and risk assessment. This session will examine the reliability and defensibility of AI-driven analyses, the potential adoption of similar tools by tax authorities, and the evolving balance between GenAI automation and human judgment. Delegates will gain practical insights into leveraging AI while navigating emerging risks in a rapidly changing TP 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