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

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.

Transition of IP Policies from Fixed to Variable Royalties

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