Topics Covered
International Tax, Transfer Pricing & Valuation - International Tax, Transfer Pricing & Valuation - How to implement and maintain inter-company transactions - How to determine your supply chain strategy - How to perform a Value Chain Analysis for tax & transfer pricing - How to locate intangibles in your value chain - How R&D activities lead to ownership of intangibles - How does your PPA influence your “future state” transfer pricing - How to deal with substance issues for IP companies - How to deal with your in-house treasury function - How to measure and remunerate procurement management functions - How to deal with Year-end Price Adjustments - What business model applies to my group captive - How to meet your benchmarking needs - How to set up a transfer pricing control framework - What events trigger valuation
Tax Technology - Tax Technology Services - How to Implement Digital Transformation in Tax - A Complete Toolkit For Future Tax Professionals
Tax Litigation & Mediation - Tax Litigation & Mediation - How to deal with Transfer Pricing Controversy - How does your PPA influence your “future state” transfer pricing
Other Challenges - How to deal with customs planning and risk management - What VAT implications are transfer pricing related - Where do TP and WHT interact - Navigating Pillar I and Amount A/B Profit Allocation Requirements - How to Comply with Pillar II Minimum Taxation Requirements - ESG Reporting for Tax Compliance - The Impact of Anti-Abuse Measures on Transfer Pricing
Trends of 2025
1
Pillar One Rules
How to apply amounts A and B in your company then the latter amount applies to a much wider group of taxpayers.
3
Enhanced CbC Reporting
Tax authorities will increase scrutiny on country-by-country reports, using technology for deeper analysis.
5
Compliance AI
AI-driven and stricter global tax rules will push multinational companies to adapt transfer pricing strategies, with a
focus on compliance and documentation.
7
Anti-Tax Avoidance Rules
Stricter anti abuse law and regulations will impact how MNEs deal with the convergence between transfer pricing and anti-abuse measures
9
Documentation Requirements
Compliance with master and local file and other requirements will expand globally.
2
Pillar Two Rules
Global minimum tax rules (15%) will force multinational companies to synchronize their transfer pricing strategies.
4
Alternative Dispute Resolution
More and more governments will accept the use of so-called ADR techniques to avoid or resolve tax disputes.
6
Technology in Tax Audits
Authorities will adopt AI and data analytics to target transfer pricing audits more effectively.
8
Transfer Pricing for Intangibles
Increased focus on the valuation of onshored intangible assets, particularly for technology &
regulated industries.
10
ESG and Transfer Pricing
Environmental and social governance (ESG) factors will start influencing transfer pricing policies as sustainability becomes more relevant.