Main Summit - Day 2 (Agenda Subject to Change)Wednesday, 18 June 2025

Start your day with coffee, croissants, and insights. Join Iñigo Arechabaleta and Pim Stohr from Zanders, along with Rika Yamane from H&M, for an informal breakfast session exploring best practices in Transfer Pricing for financial transactions—and how to automate the compliance process. They will cover:

• How H&M automated its compliance using Zanders Transfer Pricing Solution
• Key challenges in Transfer Pricing for financial transactions
• Best practices for structuring cash pools
• The growing importance of debt capacity analyses for term loans

In today’s rapidly evolving global tax environment, multinational enterprises face increasing pressure to navigate complex transfer pricing risks while adhering to heightened transparency requirements. This panel will delve into the most pressing and latest regulatory developments and enforcement trends, and their impact on operational and reputational risks. Join Randall Fox and Jason Collins of DLA Piper, Fanny Delaunay of Veralto, and Brandon de la Houssaye of Walmart, as we unpack the practical implications of these changes, from the rising scrutiny on intangible assets and business restructurings to the growing importance of robust documentation and dispute prevention strategies. Our panel of experts will also provide actionable insights on how to proactively deal with transparency challenges, mitigate risk exposure, and effectively manage compliance in an era of intensified tax authority oversight.

In the last few years we have experienced increase pressure over multinational Groups’ transfer pricing policies, which has had an immediate effect on double taxation and potential disputes. Additionally, the new international scenario with the implementation of Pillar 2 is creating even more potential double taxation. This situation has had an impact, and will result in an increase, in the number of APA and MAP’s in different countries, as well as in the organisation of Tax Administrations in this area. Join our panel where we will share our experience among different players in the market, as well as Tax Administrations, from a practical perspective.

This panel will explore the global landscape of transfer pricing controversy, including key highlights from recent international court decisions, current developments, and trends in transfer pricing enforcement. The panel will discuss recent experiences and any emerging themes in relation to transfer pricing controversies, considering also the future dispute landscape and possible avenues for preventing or resolving those disputes. Some of the topics that will be covered include: dealing with extensive information requests; IP valuations; experiences on penalties; and the use of advanced tools and data when approaching TP audits.

The session will explain how economics principles are embedded in the OECD Guidelines and show how some of those principles can help answer complex pricing questions. It will also explore some of the parallels with competition policy and the alternative sources of evidence this can offer.

Financial transaction transfer pricing has been one of the topical areas in transfer pricing enquiries/audits in Europe. We will discuss the recent development in the areas of pricing policy design, implementation, documentation and defence, with a focus on how to navigate the transfer pricing of financial transactions in the current market which is full of uncertainties.

The use of the Comparable Profits Method / Transactional Profit Split Method has become more prevalent in recent years – not justas a ‘last resort’ for the testing of outcomes, but as a set of transactions designed and implemented on a forward-looking basis. In order for such structures to be robust, legal form and economic substance need to be aligned in a way which meets the needs of wider, non-TP stakeholders. This panel will discuss practical consideration for designing, maintaining and defending profits splits, based on the panellists’ practical experience.

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. During this session Moises will explain the transfer pricing fundamentals for implementing variable TP royalty programs. His presentation will cover: (i) TP implications for IP licensing; (ii) Recent U.S. case-law that support the implementation of a variable royalty; and (iii) Practical guidelines for implementing a variable TP royalty program

This panel brings together senior tax officials from a range of jurisdictions, each with extensive experience navigating the complexities of international tax and transfer pricing. The panel will share practical insights drawn from real-world cases — highlighting what works, what doesn’t, and the lessons they've learned along the way. Expect candid perspectives on the real challenges and successes they've seen firsthand. In addition, the panel will also discuss the emerging themes and challenges that surface during the conference itself. Topics include:

• Common outcomes and challenges in MAP cases
• Managing processes and meeting critical timeframes
• The importance of transparency and cooperation in originating TP audits
• Substantive Transfer Pricing issues within the MAP context
• Practical considerations in APAs, including BAPAs and arbitration