A&M Tax Talks: Tax Policy Updates

In this episode, Bruno Aniceto da Silva, Senior Advisor at A&M, discusses the implications of the Pillar Two September 2026 Administrative Guidance dealing with explicitly conditional taxes, addressing four practical questions: what these taxes are, why they matter, how they can affect multinational groups, and what we should expect next.

For crypto-asset businesses that have not yet started implementing CARF, the first step is not necessarily to build a reporting engine. It is to determine whether the business is in scope, which entities and products require analysis, and what information is needed to support a defensible conclusion. In this episode, Mercy Joseph, Managing Director in Singapore, and Chris Kotarba, Managing Director in the United States, discuss practical steps for assessing CARF readiness. They explore how to identify whether a business may be a Reporting Crypto-Asset Service Provider, why contractual labels and product names can be misleading, and why businesses should follow the full transaction chain when determining reporting obligations. The discussion also considers the interaction between CARF, CRS 2.0 and Form 1099-DA, including the need for a common customer and transaction-data foundation while maintaining separate rules and reconciliation processes for each regime. Mercy and Chris also highlight the importance of governance, including clear accountability across Tax, Compliance, Legal, Operations, Data and Technology.

In this episode, Matt Andrew, Managing Director and Bruno Aniceto da Silva, Senior Advisor unpack why the OECD's flagship plan for taxing the digitalized economy, Pillar One, is effectively dead and debate what could replace it. They discuss what may come next: an OECD attempt at a "Pillar One Mark Two", whether the UN will take the baton, and what type of framework could finally achieve broad international consensus.

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.

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.