Our Global Tax Policy and Controversy (TPC) Group at A&M Tax is excited to introduce a new podcast series, “A&M Tax Talks: Tax Policy Updates” which delivers the latest insights and our views on the evolving tax policy landscape. This series explores timely and relevant topics, highlighting their impact on organizations and key considerations for effective planning and strategic decision-making.

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Episode 6

18 November 2025

David Letos & Josh Johnson: Australia’s New Public Country-by-Country Reporting

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.

Episode highlights:

• Overview of Australia’s Public Country-by-Country Reporting measures and objectives
• Application from 1 July 2024, including scope and de minimis thresholds
• Key disclosure requirements and narrative reporting obligations
• Publication framework and links to OECD CbC, EU Public CbC, and Pillar Two
• Exemption conditions, penalties, and immediate next steps for affected groups

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Episode 5

12 November 2025

Matt Andrew and Bruno Aniceto da Silva: BEPS Pillar Two: Envisioning the Revised Framework

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.

Episode highlights:

• The core design features of the Side-by-Side (SbS) system
• The possible changes to the substance-based tax incentives and how they can be aligned with QRTCs/MTTCs
• The key elements of the simplified ETR permanent safe-harbour

Listen to the podcast below.

Episode 4

05 November 2025

Anastasia Buettner: Reducing VAT Complexity: Rethinking Indirect Taxes and Compliance in Evolving European Business Models

In this episode, Anastasia Buettner, Managing Director from A&M Australia bring you insights into Rethinking indirect taxes and compliance in evolving European business models requires reducing VAT complexity.

Episode highlights:

• Key facts on VAT complexity highlight that routine compliance can hide recurring risks
• VAT registration insights show that regular reviews reduce costs and audit exposure
• Tax model observations stress aligning structures with evolving business needs
• Takeaways for multinationals note that simplified models boost flexibility and cut tax

Listen to the podcast below.

Episode 3

30 September 2025 

Jayde Thompson & Hang Vo: Global Minimum Tax – Latest developments on Tax Incentives and Simplified Safe Harbours

In this episode, Jayde Thompson, Managing Director and Hang Vo, Senior Director from A&M Australia’s International Tax Practice bring you the latest developments on the treatment of tax incentives under the GloBE Rules and the potential introduction of a Simplified Safe Harbour.

Episode highlights:

• Context of G7 and G20 Recent Announcements Pertaining to Pillar Two
• Meaning of Substance-Based Tax Incentives
• Existing Treatment of Tax Incentives in GloBE Rules
• Potential Design Considerations to Broaden the Tax Incentive Framework
• Proposed Introduction of a Simplified Safe Harbour
• Implications for Multinationals’ Planning, Compliance, and Incentive Strategies

Listen to the podcast below.

Episode 2

17 September 2025

Jayde Thompson & Shahzeb Panhwar: PepsiCo – Rethinking Royalties and Transactions

In this episode, Jayde Thompson, Corporate International Tax Managing Director, and Shahzeb Panhwar, Transfer Pricing Lead - Australia, unpack the Australian High Court’s landmark decision in PepsiCo, which has major implications for the tax treatment of cross-border payments involving intellectual property use. They explore how the Court’s rejection of the Australian Taxation Office’s embedded royalty argument reaffirms the primacy of arm’s length commercial arrangements in determining tax characterisation. 

Episode highlights:

• Key facts of the PepsiCo arrangements between the parties
• Royalty withholding tax and Diverted Profits Tax (DPT) implications
• Key observations and insights coming out of the decision: commercial substance, contractual arrangements, and arms-length dealings
• Takeaways for multinationals managing cross-border IP and royalty payments

Listen to the podcast below.

Episode 1

8 September 2025

Bruno Aniceto da Silva: G7 Side-by-Side (SbS) Arrangement

In this episode, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, brings to you insights about the recently announced G7's side-by-side (SbS) arrangement and discusses its implications for multinational enterprises.

Episode highlights:

• The context of the recent G7 and G20 statements
• How the Net Covered Tax Income (NCTI) interacts with Global Anti-Base Erosion (GloBE) rules
• How SbS may work and may be implemented
• Our A&M Tax Takeaways

Listen to the podcast below.

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