In this episode, Matt Andrew and Ruairi Lamb discuss the Substance‑Based Tax Incentive Safe Harbour and its role within the Pillar 2 global minimum tax framework. The conversation explores how the safe harbour is designed to preserve certain qualified tax incentives that are demonstrably linked to real economic activity, while also highlighting the practical implications for multinational groups and policymakers navigating the evolving Pillar 2 landscape.

Key topics covered include:

• How the Substance‑Based Tax Incentive Safe Harbour under Pillar Two aims to prevent GloBE top‑up tax from neutralising qualifying tax incentives.
• The key criteria for incentives to qualify—general availability and a clear link to local economic substance such as payroll and tangible assets.
• Treatment of refundable and transferable tax credits, including elective approaches and substance‑based caps.
• Implications for multinationals and governments, particularly for investment decisions, effective tax rate modelling, and asset‑intensive versus IP‑light business models

• (00:00:00) - Understanding the Substance Based Tax Incentive Safe Harbour

In this episode, Jordan Gill, International Tax Director, discusses what the extension to the pre-existing Transitional CbCR Safe Harbours means to Multinational Groups and what benefits this may have in providing technical and practical simplifications.

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

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.