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

Grab your coffee and croissants bright and early and join Inigo Arechabaleta and Pim Stohr of Zanders in this informal breakfast briefing as they present on best practices in Transfer Pricing for cash pools structures and other financial transactions. Along with a current Zanders Transfer Pricing Solution client they will explain:

• Current challenges of financial transactions transfer pricing
• Cash pool structures: best practices
• Term loans: the increased importance of debt capacity analyses
• Intra-group guarantees
• Client case study: how to automate the compliance process

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.

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

As in past years the panel for this session will consist of senior tax officials from various jurisdictions with a wide range of international tax experience. As well as covering issues and questions arising from the topics indicated below they will also seek to address as far as possible themes and concerns that arise over the course of the conference the panel will focus on the many issues arising from MAP, APA’s (including BAPA’s) and arbitration including;

• MAP etc outcomes and issues arising from them,
• Processes,
• Time limits,
• The importance of disclosure and co-operation in relation to the originating TP enquiries,
• Transfer Pricing in substance and MAP