Agenda Day 1, November 19, 2025: (see Agenda Day 2) (back to Event Summary)
(time zone used is Central European Time)
08.30 – Registration and Coffee
09.20 - The Interaction between Tariffs and Transfer Pricing
Johann Muller, Senior Transfer Pricing Expert
09.50 – The State of Pillar 1 and Unilateral DSTs
· The lack of global consensus on Pillar 1: Despite international discussions, a unified agreement on the reallocation of taxing rights remains elusive, creating uncertainty for multinational enterprises.
· The proliferation of unilateral DSTs and risks of double taxation
· The necessity of a coordinated, multilateral approach
· The potential for an EU-wide DST
· The role of international organizations in shaping tax policy
Kunka Petkova, Advisor, German Federal Ministry of Finance
10.20 – Intangibles and Valuation from a Transfer Pricing Context
Rezan Ökten, Partner / Transfer Pricing, Dentons
11.00 – Morning Coffee and Networking
11.30 – Tax Department Transformations to Stay Ahead of the Global Tax Developments
Barbara An Delputte, VP Strategic Tax & Customs, The LEGO Group
12.10 – Sponsor Session
12.50 – Corporate Experience of Adoption of Pillar 2
Pillar 2 is one of the most significant changes to the international tax landscape in decades. A global minimum tax of 15% and introduction of tax accounting concepts into tax law for the purposes of considering effective tax rates represents a fundamental shift in the way businesses are taxed. The additional global compliance and reporting obligations are significant, placing increased demands for data, on finance teams and IT systems. Many countries have now adopted Pillar 2 into domestic legislation, with the multinational and domestic top up tax rules already in effect. The panel will discuss practical suggestions on how to approach Pillar 2
Shibani Makhija, Tax Operations Director, JTI
13.30 – Lunch Break
14.30 – Using AI in a Corporate Tax & Transfer Pricing Environment
· Current use cases of AI and GenAI
· Practical examples of usage in your day-to-day work
Tim Mathey, Senior Director International Tax, Electronic Arts (EA)
15.10 – Automation of Manual Tax Provisioning Processes
Sarah Rigney, Associate Tax Director, Jazz Pharmaceuticals
15.50 – panel: The Use of AI in Tax & Transfer Pricing
GenAI and “traditional AI” is revolutionizing Transfer Pricing related work by automating complex and time-consuming processes that require understanding and analysis of both numerical/financial data as well as large volumes of content.
This discussion will showcase some practical applications that support TP professionals with demanding tasks, showcasing examples that significantly improve operational efficiency and strategic decision-making in Transfer Pricing.
Catherine Harlow, Head of Transfer Pricing, AstraZeneca
Johann Muller, Senior Transfer Pricing Expert
Tim Mathey, Senior Director International Tax, Electronic Arts (EA)
16.20 – Afternoon Coffee and Networking
16.50 – Best Practices in Managing Global Transfer Pricing Documentation
Zofia Mika, Group Head of Tax, Lipton
17.30 - Transfer Pricing Controversy & Audit Risks
· TP risk management strategies and recommendations
· The use of MAPs and APAs: insights and best practices
· Dealing with discrepancies in TP reporting (for example versus customs)
· Dealing with audits: having your inter-group data and information ready to effectively defend your position
Christian Runge, Head of Transfer Pricing and Tax Technology, Shell
18.20- panel: Tax and Transfer Pricing Dispute Resolution Strategies
· The Dispute Resolution Directive
· TP dispute resolution through MAPs
· Other dispute resolution mechanisms that may be effective
· Reducing time spent on disputes
· Practical experiences shared
Catherine Harlow, Head of Transfer Pricing, AstraZeneca
Johann Muller, Senior Transfer Pricing Expert
Erik Knijnenburg, Global Head of Tax & Transfer Pricing, H&M
18.40 – Closing Remarks and End of Day 1