Agenda Day 1, November 18, 2026: (see Agenda Day 2) (back to Event Summary)
08.30 – Registration and Coffee
09.00 - Opening Remarks from the Chair
09.10 – Insights from a Competent Authority, MAP and APA
· The Danish reopening system for transfer pricing cases
· Double tax treaty issues when dealing with MAP cases
· Some case examples
· Arbitration possibilities
Bo Darling Larsen, Head of Office, Large Companies, Danish Competent Authority
09.50 – Mindset Change in the Corporate Tax Function
This keynote addresses the mindset shift required within today’s tax function to remain relevant and impactful in a rapidly changing environment. It reflects on how tax organizations can move beyond a purely rule‑driven perspective and redefine their role through purpose, culture, and new ways of thinking. The session explores how trust, learning, adaptability, and collaboration shape the evolution of the tax function - setting the foundation for sustainable value creation
Dominik Wellmann, Global Head of Tax, Mercedes-Benz Group AG
10.30 – Lead Sponsor Session
11.10 – Morning Coffee and Networking
11.50 – The State of Pillar 1 and Unilateral DSTs
· The lack of a global consensus on Pillar 1
· The current spread of unilateral DSTs potentially leading to double taxation as some companies are faced with both corporate income tax and DST on the same income; create economic distortions, potentially disadvantaging digital companies in certain region
· Achieving a coordinated, multilateral approach to digital taxation to establish a fair, efficient and predictable tax environment for the global digital economy
Karine Halimi-Guez, Senior Vice President, Group Head of Tax, Booking Holdings
12.20 – International Tax / Pillar 2 Tool Presentation
This session introduces a web-based Pillar Two tool that covers the full compliance cycle — from group structure intake and ETR calculation to direct GIR filing. Drawing on two years of real engagements, we share why ERP integration is often the wrong starting point for CbCR-Safe-Harbour groups, where the practical pain points actually lie, and how jurisdictions are already diverging on how the GIR is technically filed.
· End-to-end: group intake → ETR calculation → GIR filing
· Lightweight data intake — no ERP integration required, built for CbCR-Safe-Harbour groups
· Multi-jurisdiction GIR output with built-in legal context and multi-language interface
Edgar Dokholian, Head of AI, Head of Inbound Tax Consulting, LOHR + COMPANY GmbH
13.00 – Public Country-by-Country Reporting for the EU and Australia
· How will public country-by-country reporting reshape tax transparency in the EU and Australia?
· What are the main technical and practical differences between the two frameworks?
· How can businesses align tax, transfer pricing, finance, legal, and communications teams for successful implementation?
· What risks/opportunities rise when tax data becomes public?
· Which actions should companies take now to enhance reporting readiness and stakeholder confidence?
Ralf Thelosen, Transfer Pricing / Tax Risk, Citco
Erik Knijnenburg, Global Head of Tax & TP, H&M
13.30 – Lunch Break
14.30 – What Tax Administrations Will Do with your P2 GloBE Data
· The exchange process (based on EU DAC-9 directive)
· Further data use for: (1) tax calculation, (2) risk assessment, (3) audit process
Piotr Piontkowski, Head of Unit, GloBE Implementation Unit, Ministry of Finance, Poland
15.00 - panel: The Recast of DAC6 and ATAD Issues
· Where is DAC6 heading, and what could a recast mean in practice?
· Which ATAD issues remain most relevant for tax and transfer pricing professionals?
· How should companies deal with complexity, uncertainty, and different interpretations across jurisdictions?
· What are the most important governance and compliance lessons for multinational groups?
· How can tax leaders balance technical compliance, business practicality, and risk management?
Erik Knijnenburg, Global Head of Tax & Transfer Pricing, H&M
Ralf Thelosen, Transfer Pricing / Tax Risk, Citco
Ravid Barzilay, VP Global Tax, Teva Pharmaceuticals
Jonathan Lacey, Director International Tax Affairs, Microsoft
15.40 – Transfer Pricing Controversy, Litigation & Audit Risks
· TP risk management strategies and recommendations
· The use of MAPs and APAs: insights and best practices
· Dealing with discrepancies in TP reporting (eg. vs customs)
· Dealing with audits: having your inter-group data and information ready to effectively defend your position
Massimo Mojana, Head of Tax Life Tech Platform, IMI
16.20 – Afternoon Break and Networking
16.50 - How to Arrive at the Right Transfer Pricing Model for your Business – a Practical View
· When does the business need a new TP model?
· Identify transactions involved and identify the economically relevant characteristics – be humble with your pre-gained knowledge, you might think you know the business but what if you don’t?
· Interview, gather info, be curious – look beyond the obvious
· Functions performed, assets used, risks assumed
Sandra Esteves, VP of Tax, Celonis
17.30 – Navigating OTP in Uncertain Environments
Current challenges and strategies to steer entities operating under adverse market conditions: weaker demand, price pressures, supply chain restrictions, tariffs and inflationary effects.
Jorge Dorantes, Head of Operational Transfer Pricing, Henkel
18.10 - TP Automation and Application of AI Tools
As transfer pricing (TP) regulations continue to intensify globally, organizations are under growing pressure to deliver consistent, auditable, and real‑time compliance. This session explores how TP automation and AI‑driven tools are reshaping the TP lifecycle—from data collection and policy design to benchmarking, documentation, and risk monitoring.
We will discuss how tax teams can leverage AI and advanced analytics to reduce manual effort, enhance data accuracy, and proactively manage TP risks, while maintaining governance and alignment with OECD and local regulatory expectations.
· Automation of end‑to‑end TP processes
· Application of AI in TP case study of Everllence
· Improving audit readiness and traceability through standardized, automated workflows
· Practical considerations for implementation: data quality, system integration, and change management
Lina Staugaite, Tax Technology Manager, Everllence (formerly MAN Energy Solutions)
18.50 – Closing Remarks, End of Day 1 / Reception