Conference programme

As jurisdictions begin to implement Pillar 2 rules, multinationals and advisors are navigating unprecedented technical, operational and strategic complexities. This panel will explore the key challenges faced during the first year of implementation, from data readiness and safe harbours to transitional rules. Panelists will also share lessons learned, emerging best practices, and practical insights on how businesses are adapting to ensure compliance while managing effective global tax rates and avoiding double taxation.

In a context of increasing global mobility and tax competition, several jurisdictions have introduced preferential regimes to attract high-net-worth individuals (HNWIs), digital nomads, and internationally mobile professionals. At the same time, the debate around a global minimum wealth tax, particularly targeting ultra-high net worth individuals (UHNWIs), has gained momentum in international fora. This panel will analyse the interaction between national attraction regimes and the emerging international tax policy agenda, including the legal, political, and technical challenges of designing and implementing a coordinated approach to wealth taxation.

The increasing sophistication of anti-avoidance rules—both general and specific—has significantly affected the way mergers and acquisitions are structured across jurisdictions. This panel will examine the practical implications of these rules on deal planning, due diligence, and post-transaction integration. Topics will include the application of GAARs, interest limitation rules, hybrid mismatch provisions, and anti-abuse clauses in domestic law and tax treaties. Panellists will share strategic approaches to mitigate risks, ensure legal certainty, and achieve tax-efficient outcomes in a rapidly evolving regulatory landscape.

The acquisition and ownership of professional sports clubs present unique tax and audit challenges, often compounded by regulatory oversight, complex revenue streams, and cross-border ownership structures. This panel will explore key issues such as the tax treatment of player transfers, image rights, sponsorship income, and stadium-related revenues, as well as the implications of financial fair play rules and public reporting requirements. Experts will also discuss how different jurisdictions address the tax risks associated with multi-jurisdictional investment structures.

The shift from a residence and source-based approach to a market-based allocation of taxing rights represents a fundamental transformation of international tax principles. This panel will discuss the implications of this shift—driven in part by Pillar One and unilateral digital services taxes—for traditional nexus concepts, profit allocation, and dispute resolution. Panellists will explore how tax authorities and multinational enterprises are adapting to new models that prioritise market jurisdictions, as well as the broader legal, economic, and policy consequences of this evolution.

The burden of proof plays a pivotal role in both tax litigation and alternative dispute resolution with tax authorities. This panel will analyse how different jurisdictions allocate the burden between taxpayers and tax administrations, and how this impacts the outcome of disputes. Particular attention will be given to evidentiary standards, the role of presumptions, and practical strategies for meeting documentation requirements in complex cross-border cases. The panel will also address how burden of proof considerations influence  the dynamics of tax mediation and settlement procedures.

Transfer pricing remains one of the most scrutinised areas in international taxation, often leading to prolonged disputes and double taxation risks. This panel will examine the key audit triggers and risk areas identified by tax authorities, including intangibles, intra-group services, and financial transactions. Panellists will also discuss effective strategies for dispute prevention—such as robust documentation, APAs and cooperative compliance—and tools for dispute resolution, including MAPs and arbitration mechanisms. Practical insights will be shared on how multinationals can navigate increasingly aggressive audit environments while maintaining alignment with OECD guidelines.

Cross-border VAT compliance is becoming increasingly complex as businesses navigate diverging rules, digital reporting obligations, and stricter enforcement across jurisdictions. This panel will address the main challenges faced by companies engaged in international trade, including issues related to place of supply, input VAT recovery, and e-commerce. Panelists will explore recent legislative developments, such as real-time reporting, e-invoicing, and the evolution of the ‘destination principle’, as well as opportunities for simplification and harmonisation. The session will also provide practical guidance on managing VAT risks and ensuring compliance in a global digital economy.

Carried interest, share-based payments, and other long-term incentive plans are essential tools in executive compensation, particularly in the private equity and asset management sectors. However, their cross-border implementation raises complex tax, legal, and reporting issues. This panel will analyse how different jurisdictions treat these incentive structures from a tax perspective, including the timing of taxation, the characterisation of income, and potential mismatches. Panellists will also address recent trends in mobility-related challenges, offering practical insights on structuring efficient and compliant incentive schemes across borders.

A series of roundtable discussions will look at recent developments in the following areas:

Topic one: International tax risks and insurance solutions: strategies for mitigating global fiscal challenges

Topic two: Artificial intelligence: challenges and opportunities in the age of automation

Topic three: Exchange of information - joint tax audits

Topic four: PE and global mobility - tax certainty

Topic five: Beneficial ownership and treaty eligibility