In this episode of the podcast series, Ed Raza, Senior Director, explains the key features of the Simplified Effective Tax Rate (ETR) Safe Harbor from the OECD’s SbS Package. The discussion highlights how the new Safe Harbor, expected to apply from 2027, is designed to ease Pillar Two compliance and emphasizes the importance of early preparation and robust tax and financial reporting processes ahead of implementation.

In this episode, Bruno Aniceto da Silva, Senior Advisor, unveil the SbS package which brings 4 new Safe Harbours related to the SbS System, the Substance Based Tax Incentives and material simplifications in the ETR calculations. These represent significant developments that may apply already as from 1 January 2026.

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