In this episode, we discuss the Pillar Two Side-by-Side System, the competitive advantages it creates for US-parented MNEs, its interaction with Article 32 of the EU Pillar Two Directive and its potential breach of EU law, the strategic position that developing countries may adopt, and the potential implications of the stocktake.

In the highly unlikely scenario that you somehow missed it, Professor Parada’s latest insightful article on the SbS Package and the Irony of Global Tax Cooperation can be accessed here: https://legalblogs.wolterskluwer.com/international-tax-law-blog/the-sbs-package-and-the-irony-of-global-tax-cooperation/

Robots are increasingly taking over jobs that were once considered safe from automation. In response, there are growing calls across the globe to impose taxes on robots.

I had the pleasure of speaking with Orly Mazur to understand whether taxing robots is really the right solution. Orly, a leading voice on robot taxation, shares her thoughts on the following questions:

• What are robots in general? How, if at all, do they differ from artificial intelligence?
• Is it possible to define robots for tax purposes?
• What is a robot tax? Is it the right policy tool, or are there better alternatives to address the concerns driving calls for such a tax?
• What would be an appropriate solution for taxing business profits derived in the source state from the digital presence of robots?

Beyond the technical bit, Orly also shares what inspired her to pursue a career in tax law within academia.

If you would like to explore the topic further, some of Orly’s amazing work on robot taxation can be accessed here:

Taxing the Robots - https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3231660

Policy Options to Address the “Robot Threat” - https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6077126

Should the rich pay wealth tax? You have likely seen this question spark intense debate in policy forums, at dinner tables, or even on LinkedIn.

Tax policy expert Sam Mitha answers this question and also shares insightful thoughts on questions such as:

• What are the main reasons wealth taxes have failed in most countries?
• Should the UK implement a wealth tax?
• Could a global minimum wealth tax curb the race to the bottom in individual income tax rates and prevent capital flight?

The ideals of Robin Hood are often used to defend a wealth tax. Would he have supported such a tax today?Tune in to the episode to hear Sam’s thoughts.

Finally, Sam shares the inspiration behind his decision to pursue a career in tax policy and the teamwork that has shaped his remarkable career.

In this episode, Edward Balaba and Ritu Bharadwaj share the motivating factors behind their decision to pursue an LL.M. in international tax law. They also get candid about the individuals who inspired them and served as guiding lights to help them navigate the many challenges of leaving their home countries to study abroad.

Finally, Ritu and Edward share their perspectives on the highly relevant topic of tax activism versus/ and tax scholarship.

The goal of this episode is to offer insights for prospective students considering an LL.M. in international tax law.

If you’re currently enrolled in an advanced programme in international tax law, why not consider starting your own podcast after completing your studies? You might, perhaps, want to test the waters before fully diving in. Every sixth episode of Cross Border Tax Radio is now available for takeover as a host. In these episodes, guests will share their experiences of pursuing an LL.M. in international tax law. If you’re interested in taking over as a host, please reach out to me via dm on LinkedIn or through email at ankuragarwalpro@gmail.com.

The topic of this episode arises from our increasingly interconnected world and the reinventing of our work practices in recent years. The era when the board of directors convened solely in fixed locations, seated around large oakwood tables to make strategic business decisions, has passed. Technology has made it easy to make strategic business decisions for corporations from virtually any location. However, a tax consequence of this convenience is the increased risk of corporations being dual-resident due to the management-based criteria of residency in domestic laws.

To navigate through this tax consequence, John Hayes shares his expert insights on crucial questions surrounding the issue of dual residency of corporations.

Beyond the technical discussion, John shares how a work-related trip to Chicago involving a major private equity firm, just a month after moving to PwC London, set him up for his remarkable career in international tax. He went on to become the partner-in-charge of the inbound international tax structuring practice of PwC UK. He also shares how a client inspired him not only to become good at what he does but also to continue doing so in his current role as an international tax consultant.

In this episode, Attorney Nana Ama Sarfo shares her expert insights on why there are still no easy answers for developing countries when it comes to choosing between Amount A of Pillar One and DSTs. She also explains the problems associated with DSTs and whether it is possible that countries could potentially design DSTs in a manner that circumvents the definition of DSTs in the MLC, thereby implementing both Amount A and DSTs?

Nana also shares how, like many other professionals, she fell into a career in tax law, the challenges she has overcome to get where she is today, and the sources of inspiration that have guided her remarkable career.

In this episode, Dr. Germaine Rekwest discusses key issues such as what drives countries to choose tax treaty partners, the costs and benefits of tax treaty negotiations, the relationship between tax treaties and foreign direct investment, and which treaty provisions are most debated by negotiators. She also shares the motivating reasons behind her career choice and her sources of inspiration.

The impact of Pillar Two on developing countries has been a prominent topic in academic circles, policy forums, and media. In this episode, Dr. Leopoldo Parada shares his expert insights on some of the aspects of Pillar Two that are frequently highlighted as advantageous for developing countries.

Dr. Parada discusses whether the STTR and the QDMTT are beneficial for developing countries. He also offers his views on the future of tax incentives and recommends the best policy options for developing countries.

But that's not all - Dr. Parada also shares his inspiring career journey and provides invaluable career tips.