Day 1 Agenda (In Development & Subject to Change)Wednesday, 4 November 2026

This opening session will bring delegates up to speed with at they need to know about the latest TP initiatives in the U.S. at IRS level with a keynote speech by John Wall, APMA Program Director, followed by the OECD's annual update address at this event, by Mayra Lucas, Head of Transfer Pricing Unit, which will provide a full international and global policy outlook. This session is of essential attendance for all transfer pricing and international tax professionals.

In keeping with previous stagings of this panel session, dedicated to the discussion and analysis of the most salient TP policy developments around the globe, we have once again assembled a distinguished group of tax officials and policy makers to share critical insights on ongoing policies as well as future ones in the works. Following on from the keynote speeches from IRS and OECD, the panel will pick up on some of the themes raised and provide their views. We will also be looking further afield and considering how key jurisdictions at the forefront of global trade, such as India, Australia and the UK are rising to the increasing challenges to the TP landscape.

When global trade routes, tariffs, and supply chains are disrupted, transfer pricing (TP) models are inevitably caught in the crossfire. In this session, panellists will explore the critical intersection of customs valuation and transfer pricing during operational realignments. Participants will learn how shifting manufacturing hubs and distribution flows trigger immediate tax and trade consequences. We will provide recommendations to help cross-functional corporate tax, customs, and TP teams proactively align operational changes with global tax strategies, allowing for business resilience amid ongoing global volatility.

Public Country-by-Country Reporting – is it a major concern or just another compliance requirement? Public CbCR isn’t exactly new, at least if you operate in Romania, but 2026 is the first year that most U.S. groups will be required to publicly publish their CbC Report, in Australia, the EU or both. This panel will discuss why countries have introduced Public CbCR, identify some of the administrative challenges businesses are facing, discuss who is involved in the preparation process, and how businesses are mitigating commercial concerns about publishing detailed country-level financial information.

This session will explore practical applications of artificial intelligence in transfer pricing, focusing on real-world use cases that organizations are deploying today. The discussion will address both the opportunities and limitations of current technologies, highlighting lessons learned from implementation efforts and the continued importance of human judgment. Attendees will gain insight into how AI is evolving from a productivity tool into an integral component of transfer pricing operating models and decision-making processes.

AI is rapidly reshaping digital infrastructures. This session will explore how AI is impacting the global value chain with an increased focus on data centers, undersea cables, and satellites. We will discuss how the underlying parameters, including a company’s specific AI use case, can yield varying adjustments to an existing value chain, ranging from de minimis changes to game-changing evolution. With the backdrop of uniqueness of the value chain changes, and the potential uncertainty of such changes, we will discuss the corresponding tax and transfer pricing implications, including emerging intercompany transaction frameworks, shifting relative value drivers, and geographic changes in entity remuneration. Finally, we will address the essential re-evaluation of DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) functions in an AI-driven ecosystem, with the objective of ensuring your transfer pricing models remain resilient for the future.