Conference programme

What is next after the side-by-side agreement? This panel will explore the future of Pillar Two and what may lie beyond, including the potential reconsideration of Pillar One, the renaissance of Digital Services Taxes, developments at the UN and responses from developing countries.

What happens to entities when their owners (and not their representatives or management) move? This panel will explore the tax consequences for business entities, as well as trusts and other organisations, when an individual owner or trust settlor/beneficiary relocates, and we will discuss relevant planning options that may be available.

As tax authorities seek to fill budget gaps in an increasingly resource constrained environment, taxpayers and advisors must adapt to a rapidly shifting administrative controversy landscape. This panel will explore the effect of shifting administrative policies on the Internal Revenue Service and other tax authorities, look at the current state of audits and administrative controversies in various jurisdictions and explore best practices for successfully resolving disputes without litigation.

This panel will walk through many of the issues du jour in cross-border M&A tax, including the effects of the One Big Beautiful Bill Act in the US, the increasing impact of anti-abuse rules on deal structures and the ongoing effects of Pillar Two. Is the US now a more desirable TopCo jurisdiction based on recent developments? Our panel will discuss all this and more.

How the tax sausage is made - this panel will look at tax policymaking and the evolving role of tax advisors in 2026 and beyond.

Are transfer pricing rules still fit for purpose? This panel will discuss emerging topics in transfer pricing, including the treatment of AI services and the digital economy, the taxation of data centres and interactions with Pillar Two, and will explore best practices for advising clients and achieving certainty in a rapidly changing world.

This panel will examine the latest developments in the taxation of investment funds. Topics will include the taxation of sovereign wealth funds and recent regulatory developments in the US and the taxation of cryptocurrency, among others.