Day 2 Agenda (In Development & Subject to Change)Thursday, 5 November 2026

As transfer pricing disputes intensify and tax authorities coordinate more closely, Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) have become critical tools for managing global tax risk. This panel brings together KPMG transfer pricing partners from the UK, India, and France alongside industry leaders to explore how multinational groups are using APAs and MAPs in practice. Delegates will gain insight into when these instruments make sense, how approaches differ across key jurisdictions, practical lessons from recent experience, and concrete steps to enhance certainty, reduce double taxation, and align controversy management with broader business strategy.

This highly interactive session will place attendees inside a live, scripted mock Mutual Agreement Procedure (MAP) negotiation based on a complex bilateral transfer pricing dispute. Using a realistic fact pattern involving unclear intellectual property ownership and misaligned profit allocation, the panel will role‑play competent authority negotiations between jurisdictions showing how positions are developed, challenged, and refined in practice. Attendees will gain a rare view into how competent authorities actually resolve cross‑border transfer pricing disputes, guided by a moderator who draws on first‑hand experience as a former competent authority team leader, and leave with concrete insights on how to prepare cases, documentation, and governance to improve the likelihood of timely, sustainable relief from double taxation.

Where is the IRS headed with transfer-pricing enforcement? In some ways, the IRS appears poised to follow the OECD’s lead. For instance, they are willing to echo DEMPE-style principles in their arguments. They have even cited OECD guidance in support of some transfer-pricing positions. In other ways, the IRS is willing to strike out on its own, whether that means invoking the US-specific economic-substance doctrine or aggressively pursuing CPM adjustments. On this panel, we will prognosticate about where IRS enforcement is headed and how taxpayers should think about managing their US TP risks in the context of a global TP policy.

This session will explore some of the most challenging and debated issues in the valuation of IP and intangible assets. Topics will include what constitutes compensable IP, differences in treatment across jurisdictions, business transfers versus IP transfers, the growing importance of substance over form, and when value creation, know-how, data, workforce capabilities, or other business attributes rise to the level of compensable intangible property. The panel will also examine the distinction between cost savings and true value drivers, drawing on recent disputes, audits, and controversy trends from around the world.

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

As AI transforms TP workflows, practitioners face critical questions: 1) how to build expertise and judgement when foundational processes become automated, 2) what skills become more valuable in an agentic age, and 3) where must humans remain in the loop and accountable for outcomes? This panel explores the machine-human dynamics of driving efficiency, rationalizing headcount, and enhancing output. Three practitioners and an AI advisor will discuss how in-house teams and firms can cultivate AI innovation while still balancing human needs, and perhaps, reshape how you think about transfer pricing skills in the age of AI.