Risk-Oriented Approach to SbS Pillar 2 Compliance and Reporting

The new EU public Country-by-Country Reporting obligations

In this episode, Andrea Groiß, Managing Director, and Janita Bach, Assistant Director will walk through the EU's new public Country-by-Country Reporting (CbCR) obligation, which reached its first major deadline on 30 June 2026. They explain who falls within scope - including non-EU-headquartered multinationals operating in the EU - what financial data must be disclosed, and how the two-step publication and disclosure process works across member states. The episode also tackles the safeguard clause, the significant penalty exposure for non-compliance, and the reputational risks that arise once tax data enters the public domain.

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.