This elite group, comprised of experts in the field, personally nominates all invitees and develops the Agenda, which forms the basis of our discussions.
Forum Overview
Dates: September 28 - 30, 2025
Location: Königstein im Taunus, Germany
The Steering Committee welcomes up to 44 senior tax lawyers and corporate tax directors who have been personally selected from around the world to participate in discussions focused on the complex landscape of transfer pricing law. This Forum provides an opportunity to explore common concerns, exchange ideas and resolve challenges faced.
Using candid, seminar-style discussion, the group shares experiences from their varied jurisdictions and engages in meaningful dialogue on the most pressing issues of the day.
2025 Steering Committee
Committee Co-Chairs
Denise has 23 years of experience, including as an IRS economist, consultant, in-house transfer pricing specialist, and a corporate finance/FP&A specialist. At Carrier Corporation, Denise is responsible for global tax risk management including monitoring the company's portfolio of tax audits/controversies and FIN48 tax reserves. In addition, Denise designed a model using "best-in-class" automation software for recharging Carrier Corporation's global WHQ services and executes these recharges to over 700 profit centers globally. Denise is also the lead TP specialist for financial transactions and valuations. Previously, Denise was responsible for global compliance with the OECD's CBCR and MF filing requirements. As a senior economist in the IRS's APMA program, she evaluated multi-billion dollar applications for advanced pricing agreements ("APAs") and negotiated agreements with foreign tax authorities on these and other double tax cases.
Denise has an MA in economics and a penchant for mathematical techniques that save time and create clarity. At M&T Bank, Denise designed a piece-wise polynomial formula that filtered balance sheet and P&L "variances to plan" in the ERP system for over 130 profit centers, reducing the monthly review effort from 400 hours to 8 hours. As a transfer pricing consultant, Denise designed an original metric using prime numbers that quantified the relative technical complexity of every mobile phone sold into the China market by all sellers over a 10 year period.
Denise has an MA in economics and a penchant for mathematical techniques that save time and create clarity. At M&T Bank, Denise designed a piece-wise polynomial formula that filtered balance sheet and P&L "variances to plan" in the ERP system for over 130 profit centers, reducing the monthly review effort from 400 hours to 8 hours. As a transfer pricing consultant, Denise designed an original metric using prime numbers that quantified the relative technical complexity of every mobile phone sold into the China market by all sellers over a 10 year period.
Himanshu Sinha leads the tax practice at Trilegal, one of India’s largest and leading full-service law firms. Himanshu has more than 20 years of experience in advising diverse range of clients on tax issues. His specialization is in the field of direct taxes – both on the advisory and controversy sides.
Committee Members
Lorraine Eden is Professor Emerita of Management and Research Professor of Law at Texas A&M University. A pioneering scholar in transfer pricing economics, with more than 200 publications and 16,000 citations, her current research focuses on transfer pricing policies and strategies of multinational enterprises in the digital economy.
Dr. Eden has been editor-in-chief of the Journal of International Business Studies, president of the Academy of International Business (AIB), and is currently dean of the AIB Fellows. She founded and ran the Transfer Pricing Aggies program at Texas A&M from 2007 to 2019.
Dr. Eden has been editor-in-chief of the Journal of International Business Studies, president of the Academy of International Business (AIB), and is currently dean of the AIB Fellows. She founded and ran the Transfer Pricing Aggies program at Texas A&M from 2007 to 2019.
Aurelio Massimiano was admitted to the Association of Chartered Accountants in 2002. He obtained an LL.M. Degree in International Tax Law at the University of Leiden, The Netherlands. He joined Maisto e Associati in 2005 after having worked with the International Tax Office of the Italian Revenue Agency. He has become partner since 2014.
Forum Director
Monica holds a Bachelor of Arts Degree in Sociology and Media Studies from Western University in London, ON.
Before joining Cambridge Forums, she spent five years working as a Senior Production Manager; leading agenda/program development and speaker acquisition for corporate conferences across North America. With a passion for project management, client relations, and event development, Monica looks to deliver and achieve great success in the Forum Director role.
Outside of the office, Monica can be found at her local Spin studio doing a workout class, planning her next travel adventure, and enjoying time with her family and friends.
CONNECT. ENGAGE. EXCEL. This is a different event, unlike any you've attended
Built on meaningful interactions and genuine connections, the Forum is the premiere gathering for preeminent leaders in international transfer pricing law.
SPONSORING THIS FORUM
The Steering Committee would like to thank the following sponsor for their support of the International Cambridge Forum on Transfer Pricing Law.
Please click the logo below to learn more about our Sponsor.
For more information please contact:
Dr. Emmanuel Llinares
Global Transfer Pricing Chair
Thank you to our Sponsor
We are pleased to announce that NERA will once again be hosting participants for a special Reception and Dinner on Monday, September 29, 2025. We would like to thank NERA for their continued support of the International Cambridge Forum on Transfer Pricing Law.
About NERA
The current highly dynamic and unpredictable business environment around the world presents multinational companies with significant challenges in planning and documenting their intercompany pricing policies. In recent years, transfer pricing issues have risen to the forefront of international tax. NERA’s transfer pricing professionals assist clients by providing independent and defensible economic analyses to define, document, and defend their transfer pricing policies.
For half a century, NERA experts have been central to client success in some of the world’s highest-profile cases related to litigation, regulation, and business challenges. Our global Transfer Pricing practice helps clients minimize tax risks resulting from transfer prices while optimizing their global supply chains. Our transfer pricing experts utilize market-based pricing techniques including value-chain and industry structure analyses, benchmarking studies, and rigorous valuation methodologies to design intercompany pricing policies grounded in sound business strategy and well-established economic principles. The results are transfer pricing solutions that meet both business objectives and arm’s-length requirements.
NERA would like to share some thought leadership pieces with you. Please visit the link below to access: Transfer Pricing Insights
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