In this episode of the podcast series, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, analyzes the impact of the 2025 update to the OECD Model Tax Convention, which will be incorporated into a revised version of the OECD Model to be published in the coming months.

Episode highlights:

• Global Mobility and clarification of circumstances under which cross-border work from a home office can give rise to a Permanent Establishment
• Introduction of a new alternative provision on the taxation of activities involving extractible natural resources
• Transfer Pricing related clarifications included in the update
• Addition of a new paragraph to the Mutual Agreement Procedure (MAP) article
• Developments relating to Exchange of Information

In this episode, Andy Winthrop, Senior Director, dives into Tariffs, Tangles, and the Hong Kong Advantage, highlighting the evolving dynamics of global trade where customs duties, shifting policies, and supply-chain challenges intersect with opportunity. He unpacks how tariffs reshape supply chains, why trade negotiations often become tangled, and how Hong Kong’s unique position as a free port provides a competitive edge. It’s an episode that considers both friction and leverage in international commerce, informed by sharp analysis and real-world insights. He also provides an overview of shifting tariff exposure and its impact on supply chains.

In this episode, David Letos, Executive Director and Josh Johnson, Senior Director from A&M Australia’s Transfer Pricing Practice bring you insights into Australia’s new Public Country-by-Country reporting rules.

In this episode, Matt Andrew, Managing Director and Bruno Aniceto da Silva, Senior Advisor delve into the latest developments in BEPS Pillar Two, anticipated to come into effect as early as January 2026.

In this episode, Anastasia Buettner, Managing Director from A&M Australia bring you insights into Reducing VAT Complexity: Rethinking Indirect Taxes and Compliance in Evolving European Business Models.

In this episode, Jayde Thompson, Managing Director and Hang Vo, Senior Director from A&M Australia’s International Tax Practice bring you the latest developments on the treatment of tax incentives under the GloBE Rules and the potential introduction of a Simplified Safe Harbour.

In this episode, we unpack the Australian High Court’s landmark decision in PepsiCo, which has significant implications for the tax treatment of cross-border payments involving intellectual property use. We explore how the Court’s rejection of the Australian Taxation Office's embedded royalty argument reaffirms the primacy of arm’s-length commercial arrangements in determining tax characterisation. Tune in to understand what this decision means for multinational enterprises and how it may shape future cross-border tax planning.

In this episode, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, brings to you insights about the recently announced G7's side-by-side (SbS) arrangement and discusses its implications for multinational enterprises.

Here is a brief outline of this episode of the podcast:

• The context of the recent G7 and G20 statements
• How the Net Covered Tax Income (NCTI) interacts with Global Anti-Base Erosion (GloBE) rules
• How SbS may work and may be implemented
• Our A&M Tax Takeaways