Conference: From Reform to Reality: The Evolution of International Taxation for Large Multinational Enterprises

The Institute of Finance of SGH, in cooperation with Columbus Private (Suisse) SA, invites you to participate in an international conference entitled:


From Reform to Reality: The Evolution of International Taxation for Large Multinational Enterprises.


Location: Warsaw School of Economics (SGH), Warsaw, Poland
Date: 21 May 2026
Participation in the conference is free of charge. The conference will be held in a hybrid format: on-site at SGH and online via Microsoft Teams. The link for online participation will be sent one day prior to the conference.


About the conference
This conference is designed as a high-level forum for discussing the changing landscape of international taxation in the era of the global minimum tax. Its primary aim is to provide participants with a comprehensive and practice-oriented insight into the implementation of the OECD Pillar Two rules, as well as their broader implications for domestic tax systems, investment policy, and cross-border business operations.
Particular attention will be given to the transition from legislative design to practical application. The discussions will explore how tax administrations and multinational enterprises are responding to the new regulatory environment, what challenges arise in day-to-day implementation, and how businesses can adapt to a post-Pillar Two reality while preserving tax certainty and investment competitiveness.
The programme will also cover major transfer pricing developments, with a strong focus on both dispute prevention and dispute resolution. Participants will gain insight into the use of instruments such as APAs and BAPAs, as well as MAP procedures and arbitration mechanisms, supported by practical examples and comparative perspectives from different jurisdictions.
By bringing together policymakers, international institutions, tax authorities, business representatives, and leading advisers, the conference aims to create a platform for substantive exchange, strategic reflection, and dialogue on the future of international tax governance.

Key thematic areas
The conference will address the most pressing developments in international taxation and transfer pricing, with particular focus on:
•    the implementation of the OECD Pillar Two framework in selected jurisdictions, including Poland and Switzerland, 
•    safe harbour mechanisms and their practical significance for multinational enterprise groups, 
•    tax incentives under Pillar Two and their impact on business location and investment decisions, 
•    qualified tax incentives and their compatibility with the global minimum tax framework, 
•    the prevention of transfer pricing disputes, including APAs and BAPAs, 
•    the resolution of transfer pricing disputes through MAPs and arbitration mechanisms, 
•    practical perspectives from tax administrations and multinational enterprises, 
•    current tax challenges faced by multinational groups operating in Central and Eastern Europe, 
•    an expert panel discussion followed by a Q&A session.

Speakers
The conference will feature distinguished speakers from the fields of international tax law, transfer pricing, and public policy, including representatives of the OECD, the European Commission, ministries of finance, tax administrations, and experienced practitioners from multinational enterprises and leading advisory firms.

Who should attend
The conference is addressed to:
•    tax directors and tax managers, 
•    in-house counsels and heads of legal departments, 
•    CFOs and finance executives, 
•    advisers to multinational enterprises, 
•    representatives of public administration, 
•    officials and experts from international organisations, 
•    academics and professionals interested in international taxation and transfer pricing. 
 

Conference programme

 

13.00-13.30 Registration & Coffee 

13.30-13.50 Opening remarks: The Global Tax Landscape in 2026 

  • dr hab. Piotr Wachowiak, prof.SGH -rector SGH
  • dr hab. Marcin Jamrozy, prof.SGH - director Institute of Finance 
  • Piotr Augustyniak -
  • prof. Vikram Chand -
  • Filliez Fabrice - Ambassador of Switzerland to Poland
     

13.50-14.40 Session 1: Pillar Two Implementation: Status Update 

Moderator: prof. Vikram Chand
 

  • dr Jakub Jankowski
  • Fabian Baumer -Swiss FTA
  • Francesco Bungaro -EU Commission
  • Jordan Peterson -OECD 
     

14.40-15.30 Session 2: Tax Incentives Under Pillar Two

Moderator: Piotr Augustyniak 
 

  • Ministry of Economy Poland (MRiT)
  • MNEs (Polish or Swiss)
  • K. Romanovska
  • dr hab. Aleksander Werner, prof.SGH
  • Francesco Bungaro - EU Commission 
     

15.30-15.50 Coffee Break  

15.50-16.40 Session 3: Preventing transfer pricing disputes – Practical experience / perspectives on APAs and other tools for Transfer Pricing

Moderator:  prof. Vikram Chand

  • CA Romania (Monica Todose, Bogdan Tudor, VC to invite)
  • CA Poland 
  • Polish MNE
  • Swiss MNE (Japan Tabacco, Coro)

 

16.40-17.30 Session 4: Resolving transfer pricing disputes – Practical experience / perspectives on MAPs and Arbitration for Transfer Pricing

Moderator: dr hab. Marcin Jamroży, prof.SGH

  • Swiss MNE (Novarits or Roche)
  • Polish MNE 
  • CA Czech
  • CA Switzerland (Ronnie)
     

17.30-18.00 Closing Remarks - discussion

Contact

if@sgh.waw.pl

 

PRELEGENTS:

Fabrice Filliez

Fabrice Filliez is a career diplomat. Prior to his appointment as Ambassador to the Republic of Poland, he served as Ambassador to the Republic of Singapore and the Sultanate of Brunei from 2018 to 2022. Previously, he served in Berne for five years at the Swiss State Secretariat for International Financial Matters with the title of Ambassador in charge of multilateral tax matters. At an earlier stage, he served as Head of the Economic and Finance Section of the Swiss Embassy in London.

Fabrice Filliez
dr hab. Marcin Jamroży, prof. SGH

Marcin Jamroży, Ph.D., Professor at SGH - University Professor at the SGH Institute of Finance, Director of the Institute of Finance since 2024, Head of the Department of Taxation, Doctor of Economic Sciences (SGH, 2015), Doctor of Laws (Adam Mickiewicz University, 2004), Doctor of Economic Sciences (Europa-Universität Viadrina, 2001), Head of Postgraduate Studies in International Taxation and Postgraduate Studies in Transfer Pricing and Tax Management.

Marcin Jamroży
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