A&M Tax Talks: Tax Policy Updates

Pillar 1 Amount B - Where are we now?

Alvarez & Marsal — Fri, 24 Apr 2026 05:17:58 +0000

In this episode, Adnan Begic will discuss a strategic overview of Pillar One Amount B, focusing on its technical framework, evolving global adoption, and the practical implications for multinational transfer pricing models.

Future Outlook and Policy Evolution

Alvarez & Marsal — Thu, 09 Apr 2026 05:26:47 +0000

In this episode, Bruno Aniceto da Silva, Senior Advisor and Kevin M. Jacobs, Managing Director, discuss potential policy implications of the Pillar Two Side-By-Side (SbS) system and other developments shaping the global tax landscape. This discussion wraps up our Pillar Two series by looking ahead to what’s on the horizon that could affect multinational corporations.

Transaction Readiness Under Pillar Two

Alvarez & Marsal — Thu, 26 Mar 2026 06:24:33 +0000

In this episode, Jayde Thompson and Hang Vo discuss what transaction readiness looks like in a Pillar Two world and how the global minimum tax is reshaping M&A activities. They explore key considerations across the transaction lifecycle—from early deal screening and threshold considerations through due diligence, structuring, effective tax rate modelling, and post-deal integration—while also reflecting on how the proposed OECD Side-by-Side Package may influence Pillar Two planning in an M&A context going forward.

Leveraging data and technology for Pillar Two and across the Direct Tax lifecycle

Alvarez & Marsal — Fri, 20 Mar 2026 03:58:49 +0000

In this episode, Shaun Lockhart and Carina Ngai discuss how Pillar Two is driving a fundamental shift in tax data, processes, and technology. They explore how organizations can integrate Pillar Two into the broader direct tax lifecycle, build a robust tax data architecture, and strengthen governance and controls, while using today’s compliance demands as a foundation for a future‑ready tax function.

Key topics covered include:

Navigating the complex and granular data requirements under Pillar Two
Integrating Pillar Two with the broader direct tax lifecycle, including tax provision and reporting
Designing a tax‑enabled data architecture and centralized tax data platform
Strengthening governance, controls, and data quality through technology and workflow
Practical next steps and a phased roadmap toward a future‑ready tax function

Risk-Oriented Approach to SbS Pillar 2 Compliance and Reporting

Alvarez & Marsal — Thu, 12 Mar 2026 13:27:24 +0000

In this episode, Jayde Thompson, Managing Director and Ed Raza, Senior Director break down the OECD’s Side‑by‑Side (SbS) Safe Harbour regime through a commercial, risk‑based lens and why it’s quickly becoming one of the most actionable opportunities in Pillar Two right now. Instead of treating this as “just another compliance simplification,” the discussion focuses on how tax leaders can use the latest package to identify structural relief, reduce unnecessary compliance effort, and prioritise the work that actually moves the ETR and Top‑up Tax outcome. They explore how to translate your Pillar Two profile into clear risk parameters across three practical fronts commercial, policy, and operational/data so organisations can move faster with confidence and avoid building overly complex processes in low‑risk areas.

Understanding the UPE Safe Harbour

Alvarez & Marsal — Fri, 06 Mar 2026 04:47:00 +0000

In this episode, Tom Lobb and David Smyth discuss the UPE Safe Harbour announced as part of the Pillar Two side-by-side package in January 2026 and its significance within the evolving global minimum tax framework. The conversation explores the policy objectives behind the safe harbour, the issues it seeks to address, and the key criteria that must be met to qualify. They also examine which jurisdictions may be positioned to benefit and outline the practical implications for multinational groups navigating the complexities of Pillar Two implementation.

Side-by-Side Safe Harbor

Alvarez & Marsal — Fri, 27 Feb 2026 12:00:02 +0000

In this episode of the podcast series, Bryan Glanzberg and Cory Terry discuss the Side-by-Side Safe Harbour and its role within the Pillar 2 global minimum tax framework. The conversation explores how the safe harbour came to be, compares and contrasts what it means for US multinational companies vs. Non-US multinational companies, including compliance, reporting and due diligence considerations as well as potential future implications for US tax policy.

Understanding the Substance Based Tax Incentive Safe Harbour

Alvarez & Marsal — Wed, 18 Feb 2026 08:12:18 +0000

In this episode, Matt Andrew and Ruairi Lamb discuss the Substance‑Based Tax Incentive Safe Harbour and its role within the Pillar 2 global minimum tax framework. The conversation explores how the safe harbour is designed to preserve certain qualified tax incentives that are demonstrably linked to real economic activity, while also highlighting the practical implications for multinational groups and policymakers navigating the evolving Pillar 2 landscape.

Key topics covered include:

How the Substance‑Based Tax Incentive Safe Harbour under Pillar Two aims to prevent GloBE top‑up tax from neutralising qualifying tax incentives.
The key criteria for incentives to qualify—general availability and a clear link to local economic substance such as payroll and tangible assets.
Treatment of refundable and transferable tax credits, including elective approaches and substance‑based caps.
Implications for multinationals and governments, particularly for investment decisions, effective tax rate modelling, and asset‑intensive versus IP‑light business models

Chapters

(00:00:00) - Understanding the Substance Based Tax Incentive Safe Harbour

The extended role of the Transitional CbCR Safe Harbours

Alvarez & Marsal — Fri, 13 Feb 2026 06:30:03 +0000

In this episode, Jordan Gill, International Tax Director, discusses what the extension to the pre-existing Transitional CbCR Safe Harbours means to Multinational Groups and what benefits this may have in providing technical and practical simplifications.

Simplified Effective Tax Rate (ETR) Safe Harbor from the OECD’s SbS Package

Alvarez & Marsal — Thu, 22 Jan 2026 05:58:49 +0000

In this episode of the podcast series, Ed Raza, Senior Director, explains the key features of the Simplified Effective Tax Rate (ETR) Safe Harbor from the OECD’s SbS Package. The discussion highlights how the new Safe Harbor, expected to apply from 2027, is designed to ease Pillar Two compliance and emphasizes the importance of early preparation and robust tax and financial reporting processes ahead of implementation.

The SbS system is here: Unboxing the SbS package

Alvarez & Marsal — Wed, 07 Jan 2026 04:50:29 +0000

In this episode, Bruno Aniceto da Silva, Senior Advisor, unveil the SbS package which brings 4 new Safe Harbours related to the SbS System, the Substance Based Tax Incentives and material simplifications in the ETR calculations. These represent significant developments that may apply already as from 1 January 2026.

The 2025 Update to the OECD Model Tax Convention: Global Mobility and Beyond

Alvarez & Marsal — Wed, 03 Dec 2025 04:14:55 +0000

In this episode of the podcast series, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, analyzes the impact of the 2025 update to the OECD Model Tax Convention, which will be incorporated into a revised version of the OECD Model to be published in the coming months.

Episode highlights:

Global Mobility and clarification of circumstances under which cross-border work from a home office can give rise to a Permanent Establishment
Introduction of a new alternative provision on the taxation of activities involving extractible natural resources
Transfer Pricing related clarifications included in the update
Addition of a new paragraph to the Mutual Agreement Procedure (MAP) article
Developments relating to Exchange of Information

Tariffs, Tangles and the Hong Kong Advantage

Alvarez & Marsal — Tue, 25 Nov 2025 05:59:57 +0000

In this episode, Andy Winthrop, Senior Director, dives into Tariffs, Tangles, and the Hong Kong Advantage, highlighting the evolving dynamics of global trade where customs duties, shifting policies, and supply-chain challenges intersect with opportunity. He unpacks how tariffs reshape supply chains, why trade negotiations often become tangled, and how Hong Kong’s unique position as a free port provides a competitive edge. It’s an episode that considers both friction and leverage in international commerce, informed by sharp analysis and real-world insights. He also provides an overview of shifting tariff exposure and its impact on supply chains.

Australian Public Country-by-Country Reporting

Alvarez & Marsal — Tue, 18 Nov 2025 05:08:16 +0000

In this episode, David Letos, Executive Director and Josh Johnson, Senior Director from A&M Australia’s Transfer Pricing Practice bring you insights into Australia’s new Public Country-by-Country reporting rules.

BEPS Pillar Two: Envisioning the Revised Framework

Alvarez & Marsal — Wed, 12 Nov 2025 05:51:13 +0000

In this episode, Matt Andrew, Managing Director and Bruno Aniceto da Silva, Senior Advisor delve into the latest developments in BEPS Pillar Two, anticipated to come into effect as early as January 2026.

Reducing VAT Complexity: Rethinking Indirect Taxes and Compliance in Evolving European Business Models

Alvarez & Marsal — Wed, 05 Nov 2025 08:18:54 +0000

In this episode, Anastasia Buettner, Managing Director from A&M Australia bring you insights into Reducing VAT Complexity: Rethinking Indirect Taxes and Compliance in Evolving European Business Models.

Global Minimum Tax – Latest developments on Tax Incentives and Simplified Safe Harbours

Alvarez & Marsal — Tue, 30 Sep 2025 05:00:00 +0000

In this episode, Jayde Thompson, Managing Director and Hang Vo, Senior Director from A&M Australia’s International Tax Practice bring you the latest developments on the treatment of tax incentives under the GloBE Rules and the potential introduction of a Simplified Safe Harbour.

PepsiCo – Rethinking Royalties and Transactions

Alvarez & Marsal — Wed, 17 Sep 2025 08:21:00 +0000

In this episode, we unpack the Australian High Court’s landmark decision in PepsiCo, which has significant implications for the tax treatment of cross-border payments involving intellectual property use. We explore how the Court’s rejection of the Australian Taxation Office's embedded royalty argument reaffirms the primacy of arm’s-length commercial arrangements in determining tax characterisation. Tune in to understand what this decision means for multinational enterprises and how it may shape future cross-border tax planning.

G7 Side-by-Side Arrangement

Alvarez & Marsal — Mon, 08 Sep 2025 15:59:00 +0000

In this episode, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, brings to you insights about the recently announced G7's side-by-side (SbS) arrangement and discusses its implications for multinational enterprises.

Here is a brief outline of this episode of the podcast:

The context of the recent G7 and G20 statements
How the Net Covered Tax Income (NCTI) interacts with Global Anti-Base Erosion (GloBE) rules
How SbS may work and may be implemented
Our A&M Tax Takeaways