Conference programme

• Treaty abuse, override, and GAAR case comparisons
• Litigation shaping private equity risk and employee mobility
• Dividend stripping litigation across Europe
• Beneficial ownership and treaty access disputes

Building off of the IP discussions on Day 1, our panel will take a deeper dive into transfer pricing developments around the world, including changes to laws in particular jurisdictions, significant transfer pricing cases, examination trends, dispute resolution tools, and planning approaches. We will focus in particular on:

• Transfer pricing and the interaction with anti-avoidance rules and recharacterisation
• Obtaining certainty through MAPs and APAs for transfer pricing and ancillary issues
• Developments on financing transactions, including guarantees
• How tax authorities are applying DEMPE today
• The interaction of transfer pricing and tariffs

Reporter

Thomas Vanhee Aurifer, Riyadh

This panel will explore how the acquisition and holding of professional sports franchises may be structured in various jurisdictions in both the domestic and cross-border ownership contexts. Unique tax and audit challenges as well as the manner in which different jurisdictions address the risks associated with multi-jurisdictional investment structures will also be discussed.

Reporter

Mark Galea Salomone WH Partners, Ta' Xbiex

• Tax treaty abuse and EU directive abuse
• Beneficial ownership
• Foreign tax credits
• Exchange of information between tax and other authorities
• EU directives and member state tax

Reporter

Karanjot Singh Khurana Lakshmikumaran & Sridharan, Delhi

This panel will explore how AI and digital assets are reshaping the global tax landscape. We will examine developments ranging from AI in audits, predictive analytics, taxpayer rights, and emerging debates on whether AI agents themselves should be taxed, to the rise of R&D and infrastructure incentives for AI, including large-scale datacentres. The discussion will also cover evolving rules for digital content, and crypto investment structures, highlighting both the opportunities and policy challenges of taxing innovation in an increasingly digital economy.

Reporter

Thomas Vanhee Aurifer, Riyadh