Against the backdrop of the OECD’s recent Side‑by‑Side Package and ongoing implementation challenges around Pillar Two, U.S. multinationals with European operations are reassessing their tax positions, compliance obligations, and long‑term structuring choices. At the same time, Europe’s digital taxation debate is far from settled, with several countries maintaining or revisiting digital services taxes (DSTs) and the United States signaling potential responses. Layered on top of this are significant EU‑level legislative shifts - including the status of key directives and the potential repeal of ATAD2 provisions targeting holding companies with insufficient substance - as well as national‑level reforms across major jurisdictions in Europe.

This panel will provide a comprehensive, practical, and forward‑looking update on these developments, offering attendees the insights they need to navigate uncertainty and plan with confidence.

The discussion will include topics like:
1. OECD Pillar Two: Implications of the Side‑by‑Side Package for U.S. Multinationals
• How the new administrative guidance reshapes effective tax rate calculations and safe harbors
• Interactions between U.S. GILTI rules and EU implementation timelines
• Practical challenges for U.S.‑headquartered groups operating across multiple EU jurisdictions
• What companies should prioritize in 2026 as compliance obligations tighten

2. Digital Services Taxes in Europe: Current Landscape and Transatlantic Challenges
• Which countries continue to apply DSTs and which are considering new measures
• The status of OECD Pillar One negotiations and the risk of unilateral action
• Potential U.S. trade or tariff responses and their implications for transatlantic firms
• How companies can prepare for divergent digital tax regimes

3. EU Tax Directives: Progress, Delays, and the Future of ATAD2
• The evolving dynamics shaping EU tax coordination
• Status updates on key directives affecting cross‑border structuring and anti‑avoidance
• The debate around reforming ATAD2 provisions targeting low‑substance holding companies
• What such reform could mean for corporate structures, financing flows, and substance requirements

4. National Tax Developments Across Europe’s Major Economies – What are the most consequential changes affecting multinational firms

 

SPEAKERS:
• Ioana Diaconescu, Head of Unit Corporate Taxation Initiatives, DG TAXUD (EUROPEAN COMMISSION)
• Orlaith Kane, Partner, ARTHUR COX
• Michiel Schul, Partner & Head of New York Office, LOYENS & LOEFF
• Vanessa Tollis, Partner, GIDE
• Thomas Heck, Partner on Secondment, PwC [Moderator]

 

TIME:
8:30 – 9:00 AM Check-in
9:00 – 10:15 AM Discussion
10:15 – 10:30 AM Networking

Note: This program is offered as an in-person event and will not be live-streamed or recorded.


Registration is closing at 2pm ET on June 8th (Monday).