Main Summit 2026 - Day 2 Agenda (In Development & Subject to Change)Wednesday, 17 June 2026

With the current work by the OECD on the pricing of intercompany services under way, our panel will engage in a discussion of services that may fall outside the typical markup on cost remuneration with a supporting TNMM analysis, such as high-value-added services or services embedded with high-value intangibles.

This panel will explore the global landscape of transfer pricing controversy, including 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 alternative avenues available for resolving those disputes and how the choice of option guides the approach to a dispute.

Although a transfer pricing case is fact specific, there is always something to be learned. In this international field, landmark court precedents have strong practical value going far beyond the individual dispute and jurisdiction. In this session, Loyens & Loeff’s transfer pricing experts will guide you through the lessons learned from the latest leading TP case law within Europe, including related TP trends, focus areas of tax authorities, dispute prevention strategies, and burden of proof principles.

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.