Pillar Two and CAMT: competing paradigms for minimum taxation

Minimum taxation has moved beyond a technical exercise and is now reshaping deal structuring, headquarters decisions and tax risk management. This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome discussed how the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two framework (including the side‑by‑side package), the US Corporate Alternative Minimum Tax (CAMT) and emerging UN‑led initiatives are redefining the international minimum tax landscape.

Released on Oct 6, 2026

The future of tax disputes and investment treaties

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome examined the developing intersection between investment treaties and tax disputes, the relationship between tax treaties and the General Agreement on Trade in Services dispute resolution, and recent developments in Mutual Agreement Procedure, including the 2026 Manual on Effective Mutual Agreement Procedures, domestic case law on the interplay between MAP and national court proceedings, as well as the evolving role of alternative dispute resolution in cross-border tax cases.

Released on Oct 6, 2026

Economic substance and GAAR: everything everywhere all at once

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome focused on the application of GAAR and the absence of economic substance by tax authorities in several countries, in particular Denmark, Spain, Canada, India and the United States, and analysed recent trends regarding the approach of tax authorities and rulings by various courts.

Released on Oct 6, 2026

Tariffs! Customs, transfer pricing and supply chain implications

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome examined recent developments in US tariff policy and their interaction with transfer pricing and supply chain structuring. The discussion covered the legal basis of tariffs, recent court judgments, taxpayer responses and practical issues relating to tariff refunds.

Released on Oct 6, 2026

Global mobility and investment funds

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome discussed the increasing importance of global mobility in the context of investment funds, focusing on the tax implications of cross-border movement of fund managers, investors and fund structures. The discussion highlighted that mobility is no longer limited to the relocation of fund entities but increasingly involves individual mobility, remote working, investor changes and structural evolution of funds.

Released on Oct 6, 2026

M&A hot tax topics

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome addressed current tax issues relevant to cross-border M&A transactions. Based on perspectives from the United States, the United Kingdom, Germany, Italy, and the Netherlands, the Co-Chairs and speakers elaborated on relevant case law, recent legislative and administrative developments, and practical deal experience.

Released on Oct 6, 2026

Don’t lose your losses: an update on NOL planning

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome focused on recent developments and practical planning considerations surrounding the use and preservation of net operating losses (NOLs) in cross-border structures, in particular, from a German, Italian, Dutch, Swiss and United States tax perspective. The speakers discussed limitations on loss utilisation, ownership changes, group relief regimes and the impact of re-organisations and M&A transactions in key jurisdictions. The discussion also highlighted emerging anti-abuse rules and the interaction of domestic NOL regimes with international tax reforms.

Released on Oct 6, 2026

Emerging company tax issues: from startup to scale

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome explored tax issues arising at every stage of a high-growth company’s lifecycle.

Released on Oct 6, 2026

Hot topics in tax treaties

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome discussed recent developments in tax treaty policy and practice, focusing on the growing divergence between the Organisation for Economic Co-operation and Development (OECD) and UN approaches, the 2025 update to the OECD Model Tax Convention, selected treaty cases and domestic developments, anti-abuse rules and recent trends in mutual agreement procedures. The discussion combined multilateral developments with practical examples from the UK, US, Portugal, Italy and Austria.

Released on Oct 6, 2026

Tax insurance in cross-border transactions and structures

This panel at the IBA’s 26th Annual US and Europe Tax Practice Trends Conference in Rome provided a comprehensive overview of tax insurance as a risk management tool in cross-border transactions and structures. The session covered the key product types available in the market, the roles of the principal players – brokers, insurers and advisers – and the underwriting process.

Released on Oct 6, 2026

Game-changing deals: the purchase and sale of sports franchises

Sports franchise investment has entered a new era. Valuations that would have seemed extraordinary a decade ago are now commonplace, and transaction activity shows no sign of slowing. This conference panel brought together practitioners from across the Atlantic to examine what is driving this phenomenon, how cross-border acquisitions are structured from a tax perspective and what unique compliance challenges arise when major sporting events land on US soil.

Released on Jul 15, 2026

Global tax disputes: evolving legal standards and strategic litigation trends

This conference panel examined the evolving landscape of tax disputes. The session explored developments in regard to the Organisation for Economic Co-operation and Development’s mutual agreement procedure and arbitration mechanisms, particularly the impact of the EU’s Directive (EU) 2017/1852 on the resolution of tax disputes. The discussion brought together diverse perspectives from the judiciary and private and corporate practice, providing insights into how tax disputes are resolved in different jurisdictions.

Released on Jul 15, 2026

Insurance in tax-critical transactions

Tax liability insurance has moved firmly into the mainstream of transactional and advisory practice. Over time it has become a recognised instrument of strategic risk management, deployed across restructurings, capital planning exercises, operational tax positions and even disputes already under active audit. This conference panel brought together practitioners from Europe and the US to examine how the market has developed, how policies are structured and negotiated, as well as what happens when things go wrong.

Released on Jul 15, 2026

M&A part two: tax risk and compliance

This conference panel discussed certain M&A considerations, whereby the panellists touched on the considerations for indirect share transfers and certain anti-abuse provisions, such as the limitation on benefits and principal purpose test. They also specifically discussed the new developments under the Organisation for Economic Co-operation and Development’s Pillar Two framework and the side-by-side agreement.

Released on Jul 15, 2026

Global distressed debt restructurings

In this conference panel, the discussion examined the tax consequences of a cross-border corporate restructuring involving a distressed European portfolio company held by a private equity fund. The panellists – practitioners specialising in US, UK, German and Dutch law – walked through a detailed hypothetical scenario and analysed the issues that arise for lenders, borrowers and the private equity sponsor at each stage of the workout.

Released on Jul 15, 2026

Navigating real estate around the world

This panel discussion was held as part of the IBA’s 15th Annual London Finance and Capital Markets Tax Conference. The session brought together real estate tax experts from Austria, Germany, Spain, Italy, the UK and the US to examine recent developments in international real estate taxation. The panellists examined current trends and challenges in regard to real estate taxation, focusing on transfer taxes, anti-avoidance measures, transparency frameworks and hybrid real estate structures.

Released on Jul 15, 2026

Securitisation transactions: what’s next after receivables, and do taxes play a role?

This conference panel discussion brought together experts from multiple jurisdictions to examine the tax considerations shaping securitisation across Italy, the US, Spain, France, Ireland, Luxembourg and the UK. The conversation covered the types of vehicles used, the tax treatment, the advantages and limitations applicable to each jurisdiction and the emerging challenges posed by the European Union’s Anti-Tax Avoidance Directives.

Released on Jul 15, 2026

Global financing under pressure: tax risks, fund structuring and regulatory hurdles?

This conference panel discussed various tax aspects of financial transactions by chronologically assessing the various steps of a financing transaction. The panel went on to discuss various fund structures, beneficial ownership, withholding taxes and interest deductibility.

Released on Jul 15, 2026

Taxes after the 2024 storm: is there a way back? The global impact of the One Big Beautiful Bill Act

This roundtable discussion was held as part of the IBA’s 15th Annual London Finance and Capital Markets Tax Conference. The panel brought together tax experts from the US, the UK and various EU Member States to examine recent developments in international tax policy, addressing the future of the Organisation for Economic Co-operation and Development’s Pillar Two framework and the G7 side-by-side system, the future of Pillar One and digital services taxes, retaliatory taxation dynamics under Sections 891, 896 and 899, potential EU responses through state aid rules, the EU Anit-Tax Avoidance Directive, transfer pricing, joint tax audits, perspectives on taxing US multinationals and the re-emergence of tax competition across jurisdictions.

Released on Jul 15, 2026

From courts to consequences: the key tax rulings driving international policy

This conference session brought together leading tax litigators and academics from multiple jurisdictions to examine recent landmark decisions shaping contemporary tax policy. The session evaluated seminal rulings cutting across themes including taxpayer rights, anti‑abuse doctrines, treaty interpretation, international administrative cooperation and the interaction between domestic appeals and mutual agreement procedure/BEPS Multilateral Instrument frameworks.

Released on Jul 15, 2026

Taxing the invisible: IP, intangibles and the future of global planning

This conference session examined the evolving global landscape for taxation of different types of intellectual property (IP), a subject that continues to sit at the centre of international tax policy and corporate structuring. The discussion brought together experts to examine how IP is characterised for tax purposes, the source and allocation rules that govern income from intangibles and the continuing impact of the Organisation for Economic Cooperation and Development’s Base Erosion and Profit Shifting measures, specifically the Pillar Two framework, on cross border IP arrangements.

Released on Jul 15, 2026

Capital in motion: funds, private equity and tax efficiency

This report summarises a panel discussion on current issues in private equity investment structuring. The panel was divided into two parts. The first part addressed entity classification and cross-border mismatches. The second part focused on operational and structural challenges, including carried interest, substance and new fund structures.

Released on Jul 15, 2026

New tax developments in Turkey in 2026

Various changes have been made to the Turkish tax system via Law No 7582 On Amendments to Certain Laws, which was published in the country’s Official Gazette on 4 June 2026. Some of the most important changes are discussed in this article.

Released on Jun 10, 2026

Data centres: the good, the bad and the ugly [Taxes Committee]

This discussion at the IBA Annual Conference Toronto 2025 looked at the explosive growth of global data generation, examining how rising AI workloads, hyperscaler expansion and power scarcity are reshaping the fundamentals of site selection, permitting, energy strategy and infrastructure planning.

Released on Feb 27, 2026

The evolution of the tax adviser’s role in Mexico within an increasingly demanding fiscal and judicial environment

This article analyses the transformation of the tax adviser’s role in Mexico within a context characterised by intensified tax enforcement, technological oversight, judicial reform and evolving client expectations. It argues that the profession has evolved from being a predominantly technical function into a strategic, preventive, interdisciplinary and ethical practice, focused on risk management and legal certainty.

Released on Feb 27, 2026

To move or not to move, taxation is the question

This panel at the IBA Annual Conference in Toronto explored the tax implications of changing residency and how tax policy, politics and personal priorities drive mobility for internationally active families and entrepreneurs. The discussion covered, among other things, exit taxes and dual residency, permanent establishment (PE), controlled foreign corporation (CFC) regimes, new tax law developments and family and succession law issues. Against a backdrop of political volatility and regulatory change, the panel distilled practical guidance drawn from recent cases and experiences in the US, Mexico, France, Spain and Israel.

Released on Feb 27, 2026

Structuring investments in the Canadian resource industry

This panel session at the IBA Annual Conference in Toronto included a discussion of considerations for inbound investments into Canadian resource companies, challenges associated with Canada’s foreign affiliate dumping regime, repatriation strategies and Canada’s unique flow-through share financing regime for early stage capital.

Released on Feb 24, 2026

Global minimum tax: pillarious but not funny

This report provides a comprehensive overview of discussions on recent developments in international corporate taxation, focusing on the implementation of the Organisation for Economic C-operation and Development’s (OECD) Pillar Two rules, the emerging side-by-side system and related legal and transactional implications. It summarises the G7’s support for the use of a side-by-side approach, potentially exempting United States multinational enterprises (MNEs) from the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR), as well as providing updates on Pillar Two adoption and adjustments in Ireland, Canada, Switzerland, Latin America and the United Kingdom. This article also highlights practical considerations for cross-border transactions, securitisations and evolving tax insurance solutions.

Released on Feb 24, 2026

Digital nomads: opportunities and challenges of a growing phenomenon

This panel session at the IBA Annual Conference in Toronto offered comprehensive analysis of the burgeoning global trend of digital nomads (DNs) and the complex legal and regulatory challenges they present both for individuals and employers. Spurred by the post-pandemic shift to remote working, the panel reviewed the rapid expansion and highly variable design of DN visa schemes worldwide.

Released on Feb 24, 2026

The medium is the message: non-judicial avenues for settling disputes and obtaining certainty

This panel at the IBA Annual Conference in Toronto explored the increasing relevance of non-judicial mechanisms in regard to resolving tax disputes and securing certainty at a time when audits are more complex, cross-border interactions more frequent, and judicial systems more strained.

Released on Feb 24, 2026