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
Miguel Pimentel Garrigues, Lisbon
Session / Workshop Chair(s)
| Richard Slowinski | Alston & Bird, Washington, District of Columbia, USA |
Speakers
| Sven-Eric Baersch | 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 | |
| Elissa Romanin | MinterEllison, Melbourne, Victoria, Australia; Vice Chair, Taxes Committee |
| Philip Tully | Matheson, Dublin, Ireland |