The Evolving Global Tax Dispute Resolution Architecture

State Aid on Trial - From Starbucks to Apple and what lies ahead?

In this session, Bruno Aniceto da Silva, Senior Advisor at A&M, together with guest speaker Prof. William Byrnes, an international tax and transfer pricing professor at Texas A&M School of Law, examines the Court of Justice of the European Union’s (CJEU) transfer pricing jurisprudence. They also explore the surprising reasoning underlying the Apple decision and its broader implications for ongoing cases, including IKEA, Nike, and Huhtamäki. The discussion provides a closer look at where EU State aid intersects with the arm’s length principle and where it may be headed next.

The Evolving Global Tax Dispute Resolution Architecture

In this episode Lucy Sauvage and Craig Aspinall discuss how global tax dispute resolution is evolving from traditional bilateral MAP processes to more complex, and potentially competing, multilateral OECD and UN frameworks.

Pillar 1 Amount B - Where are we now?

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

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

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.