Agenda Day 2, November 20, 2025:   (see Agenda Day 1)     (back to Event Summary)

09.00 – Opening Remarks from the Chair

09.00 – Setting up a Tax Governance and Control Framework

Tax risk management:  having the strategy, approach, process and reporting

Giuseppe Abatista, Group Tax Consultant and Former Group Tax Director, Ferragamo

 

09.40 - Organisation and Developments of the Dutch APA Practice 

Armine Markarian, Transfer Pricing Specialist, Dutch Tax Office

 

10.20 - The Changing Landscape of Tax Certainty: Moving from Dispute Resolution to Dispute Prevention through the OECD’s International Compliance and Assurance Programme (ICAP) 

Nicole Casey, Advisor, OECD

 

11.00 – Morning Coffee and Networking

  

11.30 - Practical Experiences during the Process of Bilateral APAs or MAPs

·        The use of MAPs and APAs:  insights and best practices

·        Overview and update of unilateral APAs

·        Overview and update of bilateral APAs

Renata Ardous, Head of Global Corporate Tax (TP and International Tax), Chanel

 

12.10 - Group Internal Financing – More than a Transfer Pricing Issue?

·        What connects external and internal financing?

·        Internal transactions are eliminated – except taxes

·        Equity – long term debt – short term debt

·        Functions of internal financing – reflections to transfer pricing

·        Case study; internal financing and risk mitigation

Lukasz Kubicki, Head of Group Tax, Selecta Group

 

12.50 - M&A Tax and Tax Structuring Challenges and Risk Management

·        Navigating anti-avoidance measures and the mountain of risks involved in tax planning (CFC rules, interest deduction, beneficial ownership rules, PEs, Pillar 2, etc)

·        Ensuring that your acquisition strucutres are flexible to be efficient and with minimual risk (financing, profit distribution, etc.)

·        Integrating your tax structuring strategy with compliance

Dalton Hirata, Head of Corporate Tax Governance and M&A, RHI Magnesita

 

13.30 – Lunch Break

 

14.30 – Leading on ESG in Corporate Tax & Preparing for Public Country by Country Reporting (pCbCR)

·        Engaging with your sustainability office, ESG controller and accounting team to lead on ESG

·        Our journey to get to a tax disclosure on pCbCR

Alu Ursu, Head of Transfer Pricing, NXP

 

15.00 - Supply Chain Optimization: Transfer Pricing, Customs, and VAT

·        Global businesses are constantly seeking ways to optimize their supply chains for greater efficiency and cost savings

·        Aligning transfer pricing, VAT, and customs strategies can unlock new savings opportunities and ensure compliance

Aline Berbari, Manager, International Tax, Joseph Ribkoff

 

15.30 – Panel Discussion:  Current Issues with Tax Department Transformation and Pillar 2

 Ravid Barzilay, VP Global Tax, Teva Pharmaceuticals

Shibani Makhija, Tax Operations Director, JTI

Ralf Thelosen, Transfer Pricing / Tax Risk, Citco

Tim Mathey, Senior Director International Tax, Electronic Arts (EA)

 

16.10 – Closing Remarks and End of Forum

(see Agenda Day 1)      (back to Event Summary)