In the wake of Pillar Two and its cross-border impacts, multinational groups are reassessing their global operating models, including the role of European holding companies, financing arrangements and the location of intellectual property (IP). At the same time, jurisdictions across Europe and the United States continue to refine their tax frameworks, reflecting evolving international tax standards and broader competitiveness considerations.
Join our panelists from Luxembourg, Ireland, the Netherlands, Switzerland and the United States as they discuss what these changes may mean for multinational groups and what multinational groups may want to evaluate when reviewing their European structures going forward.
Topics to be discussed include:
- First-year Pillar Two implementation: practical challenges and the evolving interaction between Pillar Two and key international tax provisions, such as global intangible low-taxed income (GILTI), foreign-derived deduction-eligible income (FDDEI) and foreign tax credits
- Key considerations for multinationals evaluating European regional headquarters, financing arrangements, and IP ownership models
- Tax considerations across Luxembourg, Ireland, the Netherlands and Switzerland that may affect how multinational groups evaluate their existing European structures and potential future alternatives
- Economic substance, transfer-pricing documentation and value-chain alignment across multinationals’ European footprints
Learning objectives
Discuss how multinational companies may evaluate operational, financial, location and investment considerations and identify practical approaches for assessing the changing international tax landscape.
Panelists
- Martijn Bons, Netherlands Tax Desk Leader, International Tax and Transaction Services, Ernst & Young LLP
- Deirdre Fenton, Ireland Tax Desk Leader, International Tax and Transaction Services, Ernst & Young LLP
- Paul M. Finamore, Senior Manager, International Tax and Transaction Services, Ernst & Young LLP
- Alain Horat, Switzerland Tax Desk Leader, International Tax and Transaction Services, Ernst & Young LLP
- Andres Ramirez-Gaston, Senior Manager, Luxembourg Tax Desk, International Tax and Transaction Services, Ernst & Young LLP
Moderator
- Eduardo Isidro, Luxembourg Tax Desk Leader, International Tax and Transaction Services, Ernst & Young LLP
EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax