2027 WU Global Transfer Pricing Conference

Monday, February 8, 2027

18.00 - 19.30 Welcome Reception

Tuesday, February 9, 2027

09.00 - 09.15 Welcome Address

09.15 - 10.45 Session 1: Global Transfer Pricing Developments
The year 2026 saw significant developments in transfer pricing at both the international and national levels. The OECD continued its work on intra-group services and Amount B, while the United Nations advanced its transfer pricing work programme. Developments in domestic legislation, administrative practices and case law further shaped the global transfer pricing landscape. This session will provide an overview of key global transfer pricing developments in 2026 and discuss their implications for multinational enterprises and tax administrations.

11.15 - 12.45 Session 2: Transfer Pricing and Recent Case Law

Court decisions continue to play an important role in shaping transfer pricing practice across jurisdictions. Recent cases have addressed a wide range of transfer pricing issues, highlighting the complexities of applying transfer pricing rules and the different approaches taken by national courts. These developments have important implications for multinational enterprises and tax administrations alike. This session will examine significant transfer pricing decisions from around the world and discuss their implications for transfer pricing practice.

14.00 - 15.30 Session 3: Transfer Pricing and Services

Intra-group services are among the most common transactions within multinational groups, yet their pricing continues to raise practical challenges. In June 2026, the OECD released proposed revisions to Chapter VII of its Transfer Pricing Guidelines, aiming to clarify the guidance on intra-group services and support its practical application. This session will explore the proposed changes and discuss their implications for multinational enterprises and tax administrations.

16.00 - 17.30 Session 4: Transfer Pricing and and Profit Attribution to Permanent Establishments

The attribution of profits to permanent establishments raises complex transfer pricing questions, particularly in the context of integrated cross-border business activities. The allocation of functions, assets and risks, as well as differences in international approaches, present challenges for multinational enterprises and tax administrations. This session will explore the key issues in attributing profits to permanent establishments and discuss practical approaches to addressing them.

19.00 Heurigen Dinner

Wednesday, February 10, 2027

09.00 - 10.30 Session 5: Transfer Pricing and Cash Pooling

Cash pooling arrangements play a central role in multinational treasury operations, enabling groups to manage liquidity efficiently across entities and meet short-term financing needs. These arrangements raise complex transfer pricing questions concerning the accurate delineation of transactions, the remuneration of the cash pool leader and participants and the allocation of synergy benefits. This session will explore the practical challenges of applying the arm’s length principle to cash pooling arrangements and discuss possible approaches to addressing them.

11.00 - 12.30 Session 6: Transfer Pricing and Dispute Resolution

Preventing and resolving transfer pricing disputes is essential to achieving tax certainty for both multinationals and tax administrations. Advance pricing agreements (APAs) and mutual agreement procedures (MAPs) play important roles in preventing and resolving these disputes. This session will explore practical experiences with both mechanisms, focusing on their accessibility, effectiveness and ability to provide timely tax certainty.

13.45 - 15.15 Session 7: Transfer Pricing in the Banking Industry

The banking industry presents distinctive transfer pricing challenges due to the interplay between regulatory requirements, capital allocation and integrated cross-border operations. The roles of funding, risk management and financial intermediation raise complex questions about the allocation of profits within multinational banking groups. This session will explore these industry-specific challenges and practical approaches to applying the arm’s length principle to intra-group transactions.

15.45 - 17.15 Session 8: Transfer Pricing and New Technologies
AI is opening new possibilities for transfer pricing analysis, documentation and compliance. From generative AI to AI agents, these technologies offer opportunities to support benchmarking, analyse complex datasets and assist in preparing transfer pricing documentation. Their application also raises questions about data reliability and transparency. This session will explore how multinationals and tax administrations can use AI and other emerging technologies in practice.

17.15 - 17.25 Closing Remarks

• RAFFAELE PETRUZZI (Italy/Austria)
  Managing Director, WU Transfer Pricing Center, WU Vienna
  Founder and CEO, PETRUZZI Advisory

• MATT ANDREW (New Zealand)
  University of Auckland

• ISAAC GONZALO ARIAS ESTEBAN (Argentina/Panama)
  International Cooperation and Taxation Director, Inter-American Center of Tax Administrations (CIAT)

• ROCÍO BERMÚDEZ BECERRA (Spain)
  Vice-chair, ICC Global Tax Commission, International Chamber of Commerce ICC
  Head of Transfer Pricing and Tax Policy, Repsol Group

• SVITLANA BURIAK (Netherlands)
  Associate Professor, Director, Advanced LLM Program in International Tax Law, University of Amsterdam
  Tax Dispute and Controversy, KPMG Meijburg & Co

• MUKESH BUTANI (India)
  Managing Partner, BMR Legal

• GANGSHAN CAO (China/Austria)
  Teaching and Research Associate, Institute for Austrian and International Tax Law, WU Vienna

• GABRIELA CAPRISTANO CARDOSO (Brazil/France)
  Tax Policy Adviser, Transfer Pricing Unit, OECD

• RICHARD COLLIER (United Kingdom)
  Associate Fellow, Said Business School, University of Oxford

• JOEL COOPER (Australia/United Kingdom)
  Partner, UK&I Transfer Pricing Leader, EY

• LUIS CORONADO (Singapore)
  Partner, Global Tax Controversy Leader, EY

• GIAMMARCO COTTANI (Italy/Netherlands)
  Founding Partner, NOEMA Global

• SEBASTIAAN DE BUCK (Netherlands)
  Head of Tax, Unilever

• RAHUL KUMAR DINODIA (India/United Arab Emirates)
  Group Head of Tax, SJAN Group

• IAN DYKES (United Kingdom)
  Global Transfer Pricing Leader, PwC

• LORRAINE EDEN (Canada/United States)
  Professor Emerita of Management and Adjunct Professor of Law, Texas A&M University

• MORITZ FRANK (Austria)
  Teaching and Research Associate, Institute for Austrian and International Tax Law, WU Vienna

• MATHEW GBONJUBOLA (Nigeria)
  Co-Chair, UN Tax Committee

• MARIE GODENIR (Belgium/Netherlands)
  Senior Director, Tax - EMEA, Netflix

• STEFAN GREIL (Germany)
  Division IV B 3 (Transfer Pricing and Intergovernmental Proceedings), Federal Ministry of Finance

• SEEMA KEJRIWAL JARIWALA (India)
  Partner, BMR Legal

• SANDRA KNAEPEN (Belgium)
  Global Transfer Pricing Controversy Desk Leader, EMEIA Tax Controversy Leader, EY

• GEORG KOFLER (Austria)
  Professor of International Tax Law, WU Vienna

• MARTIN LAGARDEN (Germany)
  Head of Global Transfer Pricing, Henkel AG & Co. KGaA

• MICHAEL LANG (Austria)
  Head of the Institute for Austrian and International Tax Law, Professor of Tax Law, WU Vienna

• FRANCESCO MARCONI (Italy)
  Tax International Contact Partner, Andersen

• MERCY MBITHI (Kenya)
  International Tax Adviser, Transfer Pricing, African Tax Administration Forum (ATAF)

• MICHAEL MCDONALD (United States)
  Lecturer, University of Virginia School of Law

• KRISTIN MIKOLAITIS (Switzerland)
  Head of Group Tax Controversy and Assistant General Counsel - Tax, Nestlé

• OMAR MOERER (Netherlands)
  Partner, Tax, Deloitte

• INMACULADA MUT AGUILAR (Spain)
  Deputy Head, International Tax Office, Spanish Tax Agency

• AMANDA PLETZ (United Kingdom)
  Managing Director, NERA Economic Consulting

• EPSON PRASETYO (Indonesia)
  Senior Transfer Pricing Analyst, Directorate of International Taxation, Directorate General of Taxes

• ILKA RITTER (Germany/United States)
  International Tax and Development Cooperation Branch, Financing for Sustainable Development Office (FSDO), Department of Economic and Social Affairs (DESA), United Nations

• CHRISTIAN RUNGE (Netherlands)
  Global Head of Transfer Pricing and Tax Technology/AI, Shell International

• ALEXANDER RUST (Germany/Austria)
  Professor of Tax Law, WU Vienna

• DANIEL SMITH (United States)
  Senior Director, International Tax Planning and Policy, Alphabet/Google

• GIACOMO SOLDANI (Italy/France)
  Head of Tax, EssilorLuxottica

• TRUDE STEINNES SØNVISEN (Norway)
  Director Legal International Tax, The Tax Law Department, Norwegian Ministry of Finance

• RITA SZUDOCZKY (Hungary/Austria)
  Associate Professor of Tax Law, WU Vienna

• RYOSUKE TAKEMURA (Japan/France)
  Tax Policy Adviser, Transfer Pricing Unit, OECD

• GIACINTO VALENTI (Italy)
  Head of Transfer Pricing, UniCredit

• ISABEL VERLINDEN (Belgium)
  Senior Partner, NOEMA Global

• DOMINIC VINES (United Kingdom)
  Team Leader, Transfer Pricing (APA & MAP) Team, UK Competent Authority, HM Revenue & Customs

Registration

Participation fee

The participation fee for this event is EUR 1,500.-

A 10% “early bird discount” is applicable to applications received by December 4, 2026.

A waiver on the registration fee can be granted to applications from researchers exclusively employed by an academic institution. To apply, please submit a short letter of motivation including the relevance for your research, together with your CV and a list of recent publications to: transferpricingcenter@wu.ac.at.

The participation fee covers all materials, welcome reception, dinner, lunches, coffee breaks and refreshments. Costs of travel and accommodation are not included.

Payment

You will receive an invoice for the participation fee of EUR 1,500.- (or of EUR 1,350.- in case of the “early bird discount”). We kindly ask you to transfer your payment within three weeks from the date of the invoice.

Cancellation

Any notification of cancellation of registration must be sent in writing to transferpricingcenter@wu.ac.at. In case of cancellation before January 25, 2027, the participation fee will be refunded. No refund can be made for cancellations received after this date.

Location

WU Vienna University of Economics and Business
Welthandelsplatz 1
1020 Vienna, Austria

Conference: Building LC, Ceremonial Hall 1
Welcome Reception: Institute for Austrian and International Tax Law, Building D3, 2nd floor

Campus Map

Photos

We would like to inform you that photos and/or videos will be taken at this event. They will be used to provide information about the Institute‘s activities on the website, social media channels and print materials. Should you not wish for your image to be taken, we kindly ask you to avoid the camera and/or inform Ms. Isabel Huber (isabel.huber@wu.ac.at).