15th Annual London Finance and Capital Markets Tax Conference

26 Jan - 27 Jan 2026

Session information

The price of certainty: transfer pricing in a world of scrutiny

Tuesday 27 January (1415 - 1525)

Description

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

Session / Workshop Chair(s)

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

Speakers

Sven-Eric Bärsch Flick Gocke Schaumburg , Frankfurt, Germany
Jisun Choi Skadden Arps Slate Meagher & Flom, London, England
Federico Di Cesare Lipani Legal & Tax, Milan, Italy
Mariana Eguiarte Morett Garrigues, Mexico City, Mexico
Elissa Romanin MinterEllison, Melbourne, Victoria, Australia; Vice Chair, Taxes Committee
Philip Tully Matheson, Dublin, Ireland