11th Annual IBA Finance & Capital Markets Tax Virtual Conference

17 Jan - 4 Mar 2022

Session information

Transfer pricing: anticipating and responding to new challenges


  • The key points and trends in transfer pricing litigation, including Italian Supreme Court case no 1232 (January 21 2021), Coca-Cola v IRS (November 18 2020), among others;
  • New developments in applying transfer pricing rules to financial transactions;
  • How tax authorities’ transfer pricing audits are evolving for hidden permanent establishments, forward subscription structures and other cases;
  • The changing role of profit split methods in resolving transfer pricing disputes;
  • Update on the mutual agreement procedure (MAP) and advance pricing agreement (APA) procedures; and
  • Practical issues and the impact of Covid-19 on transfer pricing and year-end adjustments.

Session / Workshop Chair(s)

Richard Slowinski Alston & Bird, Washington, District of Columbia, USA


Rezan Okten Houthoff, Amsterdam, Netherlands
Raul-Angelo Papotti Chiomenti Studio Legale, Milan, Italy; Scholarship Officer, Taxes Committee
Clifford Rand Aird & Berlis, Toronto, Ontario, Canada
Fernando Tonanni Machado Meyer Advogados, São Paulo, Brazil; Young Lawyers Programme Officer, Taxes Committee
Philip Tully Matheson, Dublin, Ireland
Monique van Herksen Simmons & Simmons, Amsterdam, Netherlands