Chair: Caroline Silberztein (France)

Secretary: Eline Gueudré (France)

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)

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: Prof. Richard Vann (Australia)

Seminar D explores the resilience and relevance of international tax treaties in growing geopolitical tensions, unilateral tax measures, and evolving trade and investment policies. The Seminar focuses on the dynamics between multilateral coordination and domestic tax sovereignty, the use of taxes as strategic or retaliatory tools, and the implications of discriminatory practices for the future of the international tax order.

Chair: Juan David Velasco (Colombia)

Secretary: Diana Calderon (Venezuela) 

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)

Chair: Prof. Dr. Xaver Ditz (Germany)

Secretary: Carolin Seibert (Germany)