The website is updated on an ongoing basis. All Chairs/Speakers listed are confirmed. All times mentioned are in the local time zone (Western European Time (WET)).
| Congress | IFA 2025 LISBON |
| Date | 5-9 OCTOBER 2025 |
Residency of legal entities for corporate income taxation. Monday 6 October, 8.30-10.30/11.15-12.15
Prof. Dr. João Félix Pinto Nogueira
Chair: Prof. Dr. Pasquale Pistone
Navigating the complexities of corporate tax residency in today's global economy presents a significant challenge for businesses and policymakers alike. IFA 2025 Main Topic One addresses tax residence, a fundamental yet often overlooked concept in modern corporate taxation. As globalization and digitalization accelerate, and the scope of domestic residency exponentially expands, the risk of triggering residency in multiple jurisdictions increases dramatically. Furthermore, the shift from "place of effective management" to mutual agreement as the treaty tiebreaker for dual residency conflicts exacerbates the potential for unresolved disputes, further endangering corporate survival as residence often triggers worldwide taxation. Whether you're a tax professional, a business leader, or simply interested in the future of corporate income taxation, this topic offers crucial insights into a matter of global relevance.
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Improper use of tax treaties and source taxation: policy, practice and beyond. Tuesday 7 October, 8.30-10.30/11.15-12.15
Prof. Dr. Jinyan Li and Prof. Dr. Eivind Furuseth
Chair: Prof. Dr. Luis Eduardo Schoueri
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Chair: Prof. Dr. Joachim Englisch
Seminar A provides insights into 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 discussion then addresses outstanding design issues, remaining policy challenges and possible reform options, with a particular view towards an eventual reconciliation of the Pillar Two concept with the reservations expressed by the United States. Another point of debate is whether there is a need to reform Pillar Two governance to meet the challenges of an increasingly complex ruleset and geopolitical shifts. Finally, the broader implications of Pillar Two implications for CIT systems and targeted anti-avoidance regimes are discussed. What are the decluttering agendas of the OECD, the EU and national governments, and are they ambitious enough?
Details on Chairs/Speakers will be available soon.
Seminar C. Tax planning, avoidance and evasion: liability of intermediaries. Tuesday 7 October, 13.15-15.15
Chair: Ms. Gabrielle Galdino-Glaeser
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: Ms. Isabel Verlinden
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.
Details on Chairs/Speakers will be available soon.
Details on Chairs/Speakers will be available soon.
Details on Chairs/Speakers will be available soon.
