Agenda Day 1, November 19, 2025: (see Agenda Day 2) (back to Event Summary)
08.30 – Registration and Coffee
09.00 - Opening Remarks from the Chairs
Rezan Okten, Partner – Transfer Pricing, Dentons Europe LLP
Jurjen Bevers, Partner – Co-head of Europe Tax, Dentons Europe LLP
09.20 – Key Policy Developments and Insights from the OECD
· Update from the OECD on key policy areas and the go forward programme of work for transfer pricing and tax certainty
· PE and TP aspects of the Global Mobility of workers
· Latest updates on the two pillar solution
· Moving from dispute resolution to dispute prevention and understanding the ecosystem of tax certainty interventions
Nicole Casey, Tax Policy Advisor, OECD Centre for Tax Policy, OECD
09.50 – The State of Pillar 1 and Unilateral DSTs
· The lack of global consensus on Pillar 1: Despite international discussions, a unified agreement on the reallocation of taxing rights remains elusive, creating uncertainty for multinational enterprises.
· The proliferation of unilateral DSTs and risks of double taxation
· The necessity of a coordinated, multilateral approach
· The potential for an EU-wide DST
· The role of international organizations in shaping tax policy
Kunka Petkova, Advisor, German Federal Ministry of Finance
10.20 – Valuation of the Invisible: Intangibles, Transfer Pricing, and the Tax Impact That Shaped the World
· How ideas, know-how, brands and other intangibles have shaped economies and global power shifts
· The challenge of valuing something you cannot see or touch
· Why transfer pricing rules struggle to keep up with intangibles
· How tax battles over intangibles, using transfer pricing as a tool, shape the global economy
· What recent cases and policy changes reveal
· What lies ahead for valuation, transfer pricing, tax, and global business
Rezan Ökten, Partner / Transfer Pricing, Dentons
Sebastian Frankenberg, Managing Counsel, Dentons Europe LLP
11.00 – Morning Coffee and Networking
11.30 – Tax Department Transformations to Stay Ahead of the Global Tax Developments
Barbara An Delputte, VP Strategic Tax & Customs, The LEGO Group
12.10 – Corporate Experience of Adoption of Pillar 2
Pillar 2 is one of the most significant changes to the international tax landscape in decades. A global minimum tax of 15% and introduction of tax accounting concepts into tax law for the purposes of considering effective tax rates represents a fundamental shift in the way businesses are taxed. The additional global compliance and reporting obligations are significant, placing increased demands for data, on finance teams and IT systems. Many countries have now adopted Pillar 2 into domestic legislation, with the multinational and domestic top up tax rules already in effect. The panel will discuss practical suggestions on how to approach Pillar 2
Shibani Makhija, Tax Operations Director, JTI
12.50 – Using AI in a Corporate (Tax) Environment – Trends & Possibilities
· Current status of AI
· Practical examples of usage in your day-to-day work
· AI and contracting
Remco Dewaerheijt, VP Tax Operations, Blue dot
13.30 – Lunch Break
14.30 – AI and Automation Implementation
· Current use cases of AI and GenAI
· Practical examples of usage in your day-to-day work
Tim Mathey, Senior Director Tax, Electronic Arts (EA)
15.10 – Best Practices in Managing Global Transfer Pricing Documentation
Zofia Mika, Group Head of Tax, Lipton
Marta Kazimierczak, Global Tax Manager, Accell
15.50 – panel: The Use of AI in Tax & Transfer Pricing
GenAI and “traditional AI” is revolutionizing Transfer Pricing related work by automating complex and time-consuming processes that require understanding and analysis of both numerical/financial data as well as large volumes of content.
This discussion will showcase some practical applications that support TP professionals with demanding tasks, showcasing examples that significantly improve operational efficiency and strategic decision-making in Transfer Pricing.
Catherine Harlow, Head of Transfer Pricing, AstraZeneca
Johann Muller, Senior Transfer Pricing Expert
Tim Mathey, Sr Director International Tax, Electronic Arts
Karine Halimi-Guez, Senior Vice President, Group Head of Tax, Booking Holdings
16.20 – Afternoon Coffee and Networking
16.50 - Automating a Local File in 10 Steps
Lennart van den Kommer, Transfer Pricing Adviser and Co-founder, Reptune
17.30 – Transfer Pricing Automations with Application of AI for International Organizations
Perspective and experience of industry
Lina Werner, Tax Technology Manager, MAN Energy Solutions
18.10 - Transfer Pricing Controversy & Audit Risks
· TP risk management strategies and recommendations
· The use of MAPs and APAs: insights and best practices
· Dealing with discrepancies in TP reporting (for example versus customs)
· Dealing with audits: having your inter-group data and information ready to effectively defend your position
Christian Runge, Head of Transfer Pricing and Tax Technology, Shell
18.40 – Closing Remarks and End of Day 1, Reception