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Scientific Programme

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Event details

Congress IFA 2025 LISBON
Date 5-9 OCTOBER 2025

Scientific Programme


Main subjects

Seminar topics

Chair: Prof. Dr. Joachim Englisch

Seminar A provides insights into the the state of play of Pillar II implementation, regarding both the substantive rules and related procedural measures. In this context, the interaction between international, regional and national standard setting and rulemaking is analyzed. The panel will furthermore discuss challenges of compliance and administration, with respect to both, data point gathering and legal issues. Implications of any eventual reconciliation between the GloBE rules and the US GILTI and CAMT regimes will be analyzed. Finally, the broader implications of Pillar II implications for CIT systems and targeted anti-avoidance regimes are discussed. Where and to what extent would “decluttering” be appropriate?

Chair: Ms. Gabrielle Galdino-Glaeser

In this seminar, we will debate the crucial intersection of taxation and sustainability, and discuss how tax fits into the evolving business and transparency paradigm shaped by historical political and economic developments, coupled with evolving societal expectations. The seminar will provide insights into the role of tax in advancing sustainable business practices and will feature perspectives from leading experts across various geographies and industries.

Chair: Ms. Isabel Verlinden

Notwithstanding their plausibility and irrespective of their materiality, intra-group services are vulnerable to challenges, controversy and litigation around deemed artificial profit shifting. There is no such thing as a cost-plus one size fits all. Selecting the right Transfer Pricing method is anything but easy. Characterization is a first conundrum in today’s world, marked by end-to-end transformation of traditional products to an on-demand, subscription or consumption-based offerings, sensor-equipped physical products exchanging data with cloud-based analytical platforms to drive value-added services etc. Classification (high-value vs. low-value) facilitates designing TP methodologies in a consistent way but cannot unambiguously accommodate the TP methodology when senior decision makers operate in a geographically dispersed way. Issues related to the benefit test, simplifications (safe harbors and standardized documentation and compliance), penalties etc. underscore the virtues of multilaterally brokered solutions and the appeal of the session for anyone appreciating the strategic role of Transfer Pricing in business planning.