Agenda Day 2, November 20, 2025: (see Agenda Day 1) (back to Event Summary)
09.00 – Characterisation of Royalty Payments - an APAC Perspective
The characterization of royalty payments remains a critical issue for international tax planning and tax controversy management. This session highlights:
· Key developments in this area including administrative guidance and case law in selected APAC jurisdictions
· Practical challenges and practical guidance for managing these risks
Chun Ying Ng, Senior Partner, Dentons Rodyk
09.20 – 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
09.50- Setting up a Controversy Strategy and Implementation in a MNE with Practical Experiences
· Focus areas
· Allocation of responsibilities
· Ensuring to make use of expertise knowledge
Jacco Bouman, Tax Director Benelux & Tax Controversy, Unilever
10.30 – Morning Coffee and Networking
11.00 - Organisation and Developments of the Dutch APA Practice
· Organization of the Dutch ruling practice (Unit International)
· APA process and key developments of unilateral, bilateral and multilateral APAs in the Netherlands
· Benefits insights and best practices regarding APAs
Armine Markarian, Transfer Pricing Specialist, Dutch Tax Office
11.40 – The Interaction between Tariffs and Transfer Pricing
Johann Muller, Senior Transfer Pricing Expert
12.20 - Practical Experiences during the Process of APAs or MAPs
· The use of MAPs and APAs: insights and best practices
· Overview and update of unilateral APAs
· Overview and update of multilateral APAs
Renata Ardous, Head of Global Corporate Tax (TP and International Tax), Chanel
13.00 – Lunch Break
14.00 - Group Internal Financing
· 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
14.30 - 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
15.00 – Panel: Current Issues with Tax Department Transformation and Pillar 2
Ravid Barzilay, VP Global Tax, Teva Pharmaceuticals
Shibani Makhija, Tax Operations Director, JTI
Tim Mathey, Senior Director International Tax, Electronic Arts (EA)
Ralf Thelosen, Transfer Pricing / Tax Risk, Citco
15.30 – Afternoon Coffee Break
15.40 - NXP's ESG and Tax Journey: Understanding Implications and Role of Group Tax
· ESG & Taxation – Developments, Definitions & Key Considerations
· ESG and Tax Intersections
· Approach undertaken – Defining material impact, jurisdictional assessments, and governance
· Description of assessments/investigations undertaken by NXP – lessons learned
· Carbon Tax and Carbon Pricing Mechanisms
· NXP’s approach in different jurisdictions
· Governance and Collaboration
· Tax Transparency and Sustainability Disclosures
• Public CbCR
• NXP’s approach to tax transparency reporting
Ala Ursu, Head of Transfer Pricing, NXP
16.10 - 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
16.40 – Closing Remarks and End of Forum