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

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