Conference programme

The EU tax omnibus package promises to represent the most significant reform of EU direct tax rules in years. This panel will explore existing challenges to the Anti-tax avoidance Directive, the Interest & Royalty Directive, the Parent-Subsidiary Directive and the Merger Directive, and the proposed changes thereto, against a backdrop of delicate geopolitical tensions, a focus on enhancing EU competitiveness, and evolving transatlantic tax relations. The discussion will explore whether the omnibus package can deliver meaningful simplification for cross-border groups and structures while maintaining effective safeguards against abuse. The panel will also address DAC6 developments and expected changes, the continued evolution of EU anti-abuse principles, and the latest decisions of the Court of Justice of the European Union affecting cross-border investment structures. Particular attention will also be paid to the interaction between these EU developments and the U.S. position, and what they mean for multinational businesses operating in an increasingly complex international tax environment.

As businesses become increasingly mobile, tax authorities continue to expand their focus on permanent establishment risk arising from cross-border workforce arrangements. This panel will explore the tax implications of remote work, home offices, employee secondments, employers of record and the increasing use of virtual employees across jurisdictions. Speakers will examine how changes in residence, including the relocation of fund managers and key decision-makers, can affect permanent establishment exposure, tax residence and profit allocation. The session will also address service PEs, evolving OECD guidance, business reorganisations and the growing challenges that mobility and modern working arrangements create for multinational businesses.

Artificial intelligence is rapidly reshaping business models, tax administration and the global economy. This panel will explore the tax implications of the AI revolution, from the infrastructure powering AI to the taxation of AI-driven businesses and services. Speakers will examine data centre incentives, energy and infrastructure costs, jurisdictional competition for AI investment and the growing debate over who should bear the cost of the AI buildout. The discussion will also consider where value is created within the AI ecosystem, including the roles of data, compute, intellectual property and customers, and the resulting challenges for transfer pricing, sourcing, permanent establishment and Pillar Two. Finally, the panel will explore emerging proposals to tax AI, including compute, token and robot taxes, as well as broader approaches aimed at balancing innovation, competitiveness and the distribution of economic gains from artificial intelligence.

As the digital asset industry and users moves into a new phase of growth, tax professionals are confronting increasingly complex issues that extend far beyond the basics of cryptocurrency taxation. This panel will explore advanced topics including DeFi transactions, staking, and other on-chain activities, as well as cross-border structuring, year-end tax accounting profit realization, restrictions on the use of losses and deductibility of expenses. Speakers will examine the employee token incentive schemes and VAT treatment beyond Bitcoin. Drawing on practical experience and cutting-edge developments, the session will focus on the challenges and opportunities shaping the future of digital asset taxation.

While private capital continues to be an active investment class, economic trends, such as increased interest rates, and geopolitical events require a more creative approach. This panel will discuss current trends in private capital, including how sponsors, fund managers and investors are actually getting deals done, from direct lending and private credit funds to continuation vehicles, NAV financings and secondary transactions. We'll dig into the tax consequences of these transactions and address associated impacts on carried interest, management incentives and founder reinvestments.

As tax authorities continue to challenge cross-border structures, holding companies remain a key focus of audits, disputes and litigation. This panel will examine emerging developments in beneficial ownership, treaty access and substance requirements, as well as recent challenges involving participation exemptions, withholding tax relief and intermediary holding structures. Speakers will explore how courts and tax authorities are applying anti-abuse principles, GAAR and economic substance tests, and discuss practical strategies for managing risk in an increasingly contentious environment.

In today’s global financial markets, taxpayers are navigating increasingly complex structures, products, tax regimes and regulatory frameworks. This panel will explore the certain domestic and cross-border tax implications of private credit and direct lending, derivative transactions, prediction market contracts, litigation financing and other cross-border financial market transactions. Speakers will discuss rules that limit the deductibility of interest, withholding taxes, beneficial ownership, transfer pricing aspects and emerging market trends. We will also examine innovative financial products, including perpetual instruments and hybrid instruments that are reshaping the capital markets landscape.

This panel is about securitizations, receivables finance and other structured finance products. Topics include VAT developments, recent ECJ case law, instant securitization, destocking transactions, retail financial products, instrument classification, and evolving market practices. The emphasis is on transactional structures used to package, transfer and finance assets in the capital markets.

As tax policy, capital markets and geopolitical priorities continue to evolve, multinational groups are reassessing where they invest, operate and locate key decision-making functions. This panel will explore the strategic drivers behind cross-border acquisitions, spin-offs and other structures, including the impact of Pillar Two, public market considerations and shifting global tax policies. Speakers will discuss rollover equity, tax attributes, post-acquisition integration and the ways businesses are adapting transaction structures to support long-term growth and value creation.

The most challenging tax issues often arise after a transaction is signed. This panel will focus on the practical execution of complex transactions, including carve-outs, demergers, tax-free reorganizations and cross-border restructurings. Speakers will examine management participation and employee incentive arrangements, tax loss preservation, separation planning, post-closing disputes and other implementation challenges that can have a significant impact on transaction value and successful execution.

Economic uncertainty, higher borrowing costs and changing tax rules continue to drive restructurings worldwide. This panel will explore debt-for-equity swaps, capital contributions, debt cancellations, financial restructurings, loss utilization, preservation of tax attributes, creditor-focused restructurings and cross-border solutions in a post-Pillar Two landscape.