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.