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.

In this episode, we unpack the Australian High Court’s landmark decision in PepsiCo, which has significant implications for the tax treatment of cross-border payments involving intellectual property use. We 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. Tune in to understand what this decision means for multinational enterprises and how it may shape future cross-border tax planning.

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.

Here is a brief outline of this episode of the podcast:

• 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