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