Chair: Prof. Dr. Joachim Englisch
Secretary: Magdalena Schwarz

Confirmed Speakers:
Barbara Angus (USA)
James Parent (Switzerland)
Thomas Quatrevalet (France)
John Peterson (OECD)
Juan Carlos Pérez Peña (Mexico)

Seminar A provides insights into the the state of play of Pillar Two implementation, regarding both the substantive rules and related procedural measures. In this context, the interaction between international, regional and national standard setting and rulemaking is analyzed. The panel will furthermore discuss challenges of compliance and administration, with respect to both, data point gathering and legal issues. Implications of any eventual reconciliation between the GloBE rules and the US GILTI and CAMT regimes will be analyzed. Finally, the broader implications of Pillar Two implications for CIT systems and targeted anti-avoidance regimes are discussed. Where and to what extent would “decluttering” be appropriate?

Chair: Prof. Dr. Andrés Báez Moreno (Germany)

Secretary:
Paula Benéitez (Spain)

Confirmed Speakers:

Prof. Xavier Oberson (Switzerland)
Prof. Ole Gjems-Onstad (Norway)
Marcos Catao (Brazil)
Prof. Dr. Roland Ismer (Germany)

This seminar will explore the resurgence of wealth taxation, focusing on comparative experiences, practical challenges, and key legal controversies that matter most to tax practitioners. Featuring leading experts across jurisdictions with experience on wealth taxation, the session will examine the design and implementation of wealth taxes, anti-avoidance strategies, and the constitutional and cross-border legal issues that shape their application, drawing on real-world examples and recent judicial decisions from across the globe.

Chair:
Philippe Malherbe (Belgium)

Secretary:
David Tipping (UK)

In principle, tax avoidance is lawful whilst tax evasion is a criminal offence and aggressive tax planning is in the grey zone.

By “intermediaries” are meant notably advisors of various regulated or unregulated professions like lawyers, accountants, tax advisers, but also, depending on the circumstances, promoters of given schemes or brokers or nominees of parties for various transactions.

Intermediaries may incur various types of liabilities, notably for avoided taxes, and professional or criminal sanctions.

How can those liabilities and sanctions be avoided? What is the difference between explaining the law and inducing its violation?

Chair: Gabrielle Galdino-Glaeser
Secretary: Rupal Maheshwari (India)

Confirmed Speakers:
Nathalie Mognetti (France)
Dirk-Jan Sinke (Netherlands)
Alex Miguel Cordova (Peru)
Prof. Peter Hongler (Switzerland)

In this seminar, we will debate the crucial intersection of taxation and sustainability, and discuss how tax fits into the evolving business and transparency paradigm shaped by historical political and economic developments, coupled with evolving societal expectations. The seminar will provide insights into the role of tax in advancing sustainable business practices and will feature perspectives from leading experts across various geographies and industries.

Details on Chairs/Speakers will be available soon.

Chair: Isabel Verlinden

Secretary: Gaspar Ndabi (Belgium)

Confirmed Speakers:
Dr. Emmanuel Llinares (France)
Dr. Raffaelle Petruzzi (Italy)
Rocio Bermudez (Spain)
Daniel Prates (Brazil)
Richard Lombard (Ireland)
Ivan Diaz-Barreiro (Mexico)
Shikha Gupta (India)

Notwithstanding their plausibility and irrespective of their materiality, intra-group services are vulnerable to challenges, controversy and litigation around deemed artificial profit shifting. There is no such thing as a cost-plus one size fits all. Selecting the right Transfer Pricing method is anything but easy. Characterization is a first conundrum in today’s world, marked by end-to-end transformation of traditional products to an on-demand, subscription or consumption-based offerings, sensor-equipped physical products exchanging data with cloud-based analytical platforms to drive value-added services etc. Classification (high-value vs. low-value) facilitates designing TP methodologies in a consistent way but cannot unambiguously accommodate the TP methodology when senior decision makers operate in a geographically dispersed way. Issues related to the benefit test, simplifications (safe harbors and standardized documentation and compliance), penalties etc. underscore the virtues of multilaterally brokered solutions and the appeal of the session for anyone appreciating the strategic role of Transfer Pricing in business planning.

Chair: Ana Paula Dourado (Portugal)

Chair: Xaver Ditz (Germany)

Chair: Franklin Cachia (Malta)

Speakers:

Andreia Barbosa (Portugal)
Elizabeth Gonzalez Gasca (Mexico)
Leonardo Pignatari (Brazil)
Juan Manuel Vazques (Argentina)
Didier Nsanzineza (Switzerland)

Chair: 
Pia Dorfmueller (Germany)

Speakers:
Ana Claudia Akie Utumi (Brazil)
Susanne Schreiber (Switzerland)

Mergers and acquisitions (M&As) can be an effective way for organizations to achieve strategic goals. But the complexities of international laws, regulations, and talent integration can threaten the success and outcome of global deals.

There are four key areas of the transaction: (i) the pre-contract period (including the non-disclosure agreement, term sheet, exclusivity agreement and due diligence process); (ii) the key legal documentation of the Transaction (i.e., the share purchase agreement or business/asset purchase agreement, the disclosure letter and the guarantee); (iii) signing and completion of the Transaction; and (iv) other considerations such as finance, antitrust, employment.

M&A tax considerations are crucial in any deal, especially in international transactions. They involve analyzing and quantifying tax risks and opportunities, structuring deals to minimize tax liabilities, and managing post-closing tax implications.

The scope of tax tasks in M&A transactions has changed over the last decade and new international tax developments, such as Pillar 2 and transfer pricing, do not only add to the complexity but also have in impact on the purchase agreements.

The analysis will draw on jurisdictions where significant experience with complex M&A transactions do exist, ensuring representation from key OECD countries and comparative law experts. Key topics will include:

· impacts of Pillar 2 on structuring and contractual allocation of risks in sale and purchase agreements (SPAs) and shareholder agreements,

· the types of disputes that may emerge as a result of Pillar 2,

· the impacts of transfer pricing, and

· the tax consequences of indirect transfers and the determination of beneficial ownership.