Conference programme

Leading in-house tax executives will discuss the practical realities of operating in an increasingly complex international tax environment. This panel will examine Pillar Two implementation experiences, GAAR and GIR filing challenges, the status of objections and disputes arising from Pillar Two assessments and the implications of evolving global tax policy initiatives, including Side-by-Side. Speakers will also discuss the growing use of AI within tax departments, increasing tax audit activity, controversy management strategies, tax transparency and disclosure obligations and the key issues shaping corporate tax decision-making in the years ahead.

This session will be held under Chatham House Rules.

A growing number of multinational groups are reconsidering their corporate residence and headquarters structures. This panel will examine U.S. domestications, redomiciliations, migration transactions, exit taxes, Section 367 considerations, public market access, Pillar Two implications and alternative approaches for achieving strategic and tax objectives without changing corporate nationality.

As tax authorities increase their focus on transfer pricing, businesses face unprecedented scrutiny over their cross-border arrangements. This panel will explore recent transfer pricing developments affecting business restructurings, cross-border migrations, increasingly complex global operating models, and the current regulatory environment. Speakers will also discuss transfer pricing audits, dispute resolution options, such as MAP proceedings and APAs, and recent litigation developments.

Recent court decisions and audit activity are redefining international tax controversy. This panel will examine major cases involving beneficial ownership, treaty interpretation, foreign tax credits, permanent establishments, withholding taxes, abuse principles and MAP proceedings, while also addressing audit trends, information gathering powers and evolving approaches to dispute resolution.

Tax authorities worldwide are increasingly deploying Anti-Money Laundering (AML) frameworks and the pursuit of other financial crimes in criminal tax investigations and prosecutions. Whether it is following the money across borders and along the blockchain or investigating the evasion of tax owed to a foreign jurisdiction, criminal tax investigations are expanding beyond traditional tax crimes and incorporating new investigative tools and sanctions along the way. This panel will explore the rapidly evolving global trend where tax evasion and financial crimes converge, transforming what may appear to be standard tax disputes into high-stakes criminal liabilities. Using cases ripped from the headlines, the panellists will break down the conduct and alleged violations, and discuss how cross-border cooperation, enhanced corporate transparency mandates, and aggressive regulatory enforcement are reshaping defence strategies. Attendees will gain critical insights into the modern enforcement playbook, the shifting definition of tax and financial crimes as money laundering predicates, and the proactive measures corporate executives, professional advisors, and legal counsel must take to mitigate global exposure.