Chair: Caroline Silberztein (France)

Secretary: Eline Gueudré (France)

Speakers:

Dr. Ulf Andresen (Germany)
Alyne Bernardi (Brazil)
Shigeki Minami (Japan) 
Saranee de Silva (OECD) 
Dirk Suringa (USA) 
Jerome Tse (Australia) 

Seminar A will address the most challenging contemporary issues in transfer pricing of intangibles. It will review the evolution of the definition of intangibles for transfer pricing purposes, including similarities with and differences from the notion of royalties for treaty and withholding tax purposes. A large part of the discussion will focus on the notion of “DEMPE” functions and its relevance for transfer pricing of intangible transactions, as well as disputes arising when the concept is used to characterize a business restructuring or IP transfer. Panelists will also review some important valuation questions that have arisen in recent transfer pricing cases.

Chair: Rachel Saw (Malaysia)

Secretary: Mei-June Soo (Malaysia) 

Speakers:

Marine Dupas (France) 
Marc André Gaudreau Duval (Canada)
Rhys Jewell (Australia) 
Remo Keller (Switzerland) 
Diego Riesco (Argentina) 
Jonathan Schwarz (UK) 

Seminar B addresses one of today’s most pressing international tax questions: how to determine individual tax residence in a world where people move faster than the rules governing them. With jurisdictions applying increasingly divergent residence tests, taxpayers face growing uncertainty — from stricter day-count monitoring to subjective centre-of-vital-interests assessments — and greater reliance on MAP-based tie-breaker determinations under Article 4. 

The panel will examine the effects of digital nomadism, remote work, and investment-migration schemes on residence outcomes, as well as the spillover of inconsistent rules into income tax, VAT/GST, and wealth and succession taxes. The session concludes with emerging developments in exit and trailing taxes and the broader debate over who should tax highly mobile individuals. 

Chair: Sebastiaan De Buck (Netherlands)

Secretary: Jenny Du (Australia/New Zealand) 

Speakers:

Paolo Valerio Barbantini (Italy)
Sandra Farhat (Australia)
Daniel Goff (USA) 
Nick Jones (UK) 
Michelle de Niese (Australia) 
Prof. Dr. George L. Salis (USA) 

The Panel will bring together Head of Taxes from diverse Multinational Companies, International Organizations, and Tax Authorities to bring diverse and engaging perspectives in relation to significant recent and evolving international tax and compliance developments.

It will address the topics primarily from two key angles and how this is influencing organisations, resources, processes, capabilities, and finally actual tax and transfer pricing positions: more specifically; the role of People & Functions and Data & Technology.

Chair: Mukesh Butani (India) 

Secretary: Matt Parkes (UAE)

Speakers:

Catalina Hoyos Jiménez (Colombia)
Prof. Chang Hee Lee (South Korea)
Ruud De Mooij (IMF)
Nora Morales (Mexico)
Chetan Rao (UN) 

Seminar D will focus on the interconnection between tax, trade, and investment and how they shape the economic and regulatory landscape in a highly globalized world.  This seminar will explore how developments in international tax governance, trade policy, tariffs, investment protection, and territoriality interact with one another, and how these interactions affect legal certainty, competitiveness, fiscal sovereignty, and cross-border commerce. The panel will consider the role of tax treaties, non-discrimination principles, tariffs and emerging geopolitical trade measures, with reference to recent case law (e.g., Oracle, Tiger Global). Seminar D aims to provide the audience with a perspective on how a coordinated international system can balance the protection of national tax bases with the need to support open, fair and sustainable international economic relations.

Chair: Prof. Guglielmo Maisto (Italy)

Secretary: Cesare Silvani (Italy)

Speakers:

Sandra Benedetto (Chile)
Rebecca Burch (USA)
Chloe Burnett SC (Australia) 
Dr. Eva Frehner (Switzerland) 
Shefali Goradia (India) 
Carmel Peters (New Zealand)
John Peterson (OECD) 
Prof. Frank Pötgens (Netherlands) 
Saranee de Silva (OECD)

The seminar will open with an interview with John Peterson, Head of the Cross-Border and International Tax Division at the OECD. The interview will cover policy developments and practical issues that deserve attention from the OECD’s perspective, including updates on the OECD’s programme to expand bilateral APAs beyond transfer pricing into treaty application.

Following the interview, the panel will address three international tax topics: (I) home office and global mobility, in light of the 2025 update to the OECD Commentary on Article 5; (II) Pillar Two; and (III) tax treaty interpretation issues.

Chair: Juan David Velasco (Colombia)

Secretary: Diana Calderón Manrique (Venezuela) 

Speakers:

Sahel A. Assar (USA) 
Andrea Bazzo Lauletta (Brazil) 
Dr. Paolo Ludovici (Italy) 
Prof. Daniela Hohenwarter-Mayr (Austria) 
Abhishek Maratha (India) 
Dr. Elie Roth (Canada)

Seminar F focuses on the role of trusts, foundations, and similar vehicles in family business governance and cross-border succession planning. The panel will examine entity-based planning approaches, including classification issues and the varied tax treatment of these structures across jurisdictions. Attention will also be given to national reliefs for business transfers, the taxation of unrealized gains at death, and planning strategies to mitigate related exposure. The seminar will further address cross-border succession issues such as the risks of double taxation on death, including the interpretation of inheritance tax treaties and their interaction with income tax agreements.

Chair: Prof. Dr. Ana Paula Dourado (Portugal)

Secretary: Dr. Federica Casano (UK)

Speakers:

Benjamin Angel (EC) 
Prof. Paolo Arginelli (Italy) 
Laurence Jaton (France)
Prof. Dr. Dr. Dres h.c. Juliane Kokott (CJEU) 
Claes Lundgren (Sweden) 
Prof. Rita Szudoczky (Austria/Hungary) 

This seminar will examine the evolution of the European Union's tax relations with third countries, focusing on the balance between market openness and the protection of the EU's tax base and economic interests. It will explore the legal framework governing third-country situations, including the free movement of capital, the role of international agreements, and the approach adopted by the Court of Justice of the European Union. The discussion will then consider more recent developments reflecting the EU's increasingly protective stance, including the EU list of non-cooperative jurisdictions, the Carbon Border Adjustment Mechanism, the Foreign Subsidies Regulation, and anti-tax avoidance measures affecting third countries.

Finally, panelists will assess the implications of current EU and OECD initiatives, including the Omnibus Package and Pillar Two developments, for businesses operating in a global economy. 

Chair: Prof. Dr. Xaver Ditz (Germany)

Secretary: Carolin Seibert (Germany)

Speakers:

Peter von Burg (Switzerland)
Jorge Eduardo Correa Cervera (Mexico)
Prof. Dr. Kasper Dziurdź (Netherlands/Austria/Poland)
Bruna Camargo Ferrari (Brazil) 
Ignacio Gordillo (Spain)
Denise Honey (Australia)
Judge Eui Young Lee (South Korea) 
Dieudonné Nzafashwanayo (Rwanda) 
Joshua Odintz (USA) 
Dr. Dhruv Janssen-Sanghavi (India) 

In Seminar H, recent judicial decisions from various countries in the field of international taxation will be analysed and discussed. The seminar will address a wide range of topics, including tax treaties, transfer pricing, and domestic tax rules with cross-border implications. National tax experts will present the decisions, share their perspective, and open them up for discussion.

Chair: Prof. Isabelle Richelle Graulich (Belgium)

Speakers:

Anne Gordon (USA)
Tingting Guo (China)
Lizelotte De Maeyer (Belgium)

The WIN Seminar will cover practical insights into cross-border tax recovery and enforcement. The panel will examine measures that countries can adopt to secure tax recovery abroad, as well as the legal arguments available to taxpayers.  We will debate the importance of and mechanisms for international collaboration, the complexity of tax recovery in both a timing context and with a domestic policy overlay, as well as the impact of technology on recovery.

Co-Chairs: Prof. Dr. Adolfo Martín Jiménez (Spain), Shefali Goradia (India)

Speakers:

Stephen Dodshon (Australian Taxation Office)
Anette Landén (Swedish Tax Agency)
Dr. Andrea Laura Riccardi Sacchi (Uruguayan Tax Administration)
Dirk Jan Sinke (VNO-NCW) - Speaker
Daniel Smith (Google / Alphabet)
Peetinuch Tong Utaiwan (Netflix) 

The Tax Directors' Lunch Dialogue will focus on trust, compliance and managing complexity in dialogue with the tax administrations. The session will bring together three representatives from tax administrations and three from business. The goal is to explore forward-looking solutions, foster mutual understanding, and identify ways to strengthen cooperation between business and government stakeholders.

Co-Chairs: Prof. Dr. Adolfo Martín Jiménez (Spain), Prof. Frank Pötgens (Netherlands)

Speakers:

Patricia Brown (USA) 
Prof. Dr. Xaver Ditz (Germany)
Prof. Dr. Florian Haase (Germany) 
Prof. Dr. Jérôme Monsenego (Sweden) 
Prof. Luís Eduardo Schoueri (Brazil)
Edwin Visser (Netherlands)

The TLP Lunch Dialogue will mark the conclusion of the 2026 edition of the TLP, which focused this year on the timely and complex debates surrounding withholding taxes. During this concluding session, TLP lecturers will reflect on the key insights and outcomes of the lectures and discussions held throughout the year.

Chair: Prof. Dr. Adolfo Martín Jiménez (Spain)

Speakers:

Ruud De Mooij (IMF)
John Peterson (OECD)
Chetan Rao (UN)
Dr. Veerinderjeet Singh (ICC) 
Marcio Verdi (CIAT)

This website is continuously updated with the latest information, and we will provide further details shortly.

Join  the official launch event, which will comprise the book presentation and conversation amongst the editors and authors, guided by the IFA Permanent Scientific Committee. 

IFA book on “Tax Treaty Interpretation in light of the Vienna Convention on the Law of Treaties'“ is written by distinguished IFA Members and published by the IBFD.

Chief editors:
Prof. Dr. Robert Danon
Former Chair of the Permanent Scientific Committee (PSC) of IFA
Prof. Dr. Guglielmo Maisto
Honorary President of Global IFA
Prof. Dr. Adolfo Martín Jiménez
Chair of the Permanent Scientific Committee (PSC) of IFA

Contributors:
Chloe Burnett SC, Prof. Dr. Robert Danon, Jennifer Davies, Prof. Sjoerd Douma, Jean-Blaise Eckert, Prof. Craig Elliffe, Bruno Gibert, Prof. Daniel Gutmann, Prof. Dr. Johann Hattingh, Prof. Dr. Adolfo Martín Jiménez, John Avery Jones, Prof. Dr. Dr. h.c. Michael Lang, Prof. Dr. Guglielmo Maisto, Prof. Dr. Katerina Perrou, Prof. Dr. Pasquale Pistone, Richard Xenophon Resch, Prof. Dr. Stef van Weeghel, Prof. Scott Wilkie.