08:45 - 09:25 - Registration
09:25 - 09:30 - Welcome - John Vella (Oxford University Centre for Business Taxation)
Session 1: What comes after Pillar 1?
09:30 - 11:00
US Treasury officials have signalled a willingness to re-engage with the unresolved policy question of how best to address the tax challenges arising from the digitalisation of the economy. At the same time, they have indicated that any renewed discussion should be “different” from the previous round. If Pillar One is no longer the answer, what might take its place? This session examines alternative approaches that could be pursued in place of Pillar One. The original objectives of Pillar One will be considered, as well as the policy, political, and technical challenges encountered in its development, with a view to drawing lessons from that experience.
Chair: Michael Devereux (Oxford University Centre for Business Taxation)
- Silke Bruns (Federal Ministry of Finance, Germany)
- Richard Collier (Oxford University Centre for Business Taxation)
- Wolfgang Schön (MPI, Munich)
- Achim Pross (OECD)
11:00 - 11:30 - Coffee Break
Session 2: The Side-by-Side Package: where does it leave GloBE?
11.30-13.00
The Side-by-Side Package agreed in January 2026 appears to have resolved a political impasse, but it raises important general questions about the GloBE project. This session seeks to understand how the Side-by-Side Package will shape the decisions of firms and governments: Will it confer a competitive advantage on US MNEs or just the opposite? Will it incentivise countries to repeal their QDMTTs? Could it destabilise the existing equilibrium, and if so, is a new stable equilibrium likely to emerge? How significant could Substance Based-Tax Incentives be for MNEs and for states wishing to compete? And what impact will they have on GloBE’s objectives?
Chair: Giorgia Maffini (PwC)
- John Vella (Oxford University Centre for Business Taxation)
- Niels Johannesen (Oxford University Centre for Business Taxation)
- Pierce O’Reilly (OECD)
- Conrad Turley (KPMG)
13:00 - 14:00 - Lunch
Session 3: Loughlin Hickey Annual Lecture: Wicked Double Taxation
14.00-15.00
Recent years have seen a proliferation of international double taxes, in the form of tariffs, digital services taxes, UTPR top-up taxes, and many others. Double taxes are widely, and correctly, understood to be wicked; but it is important to identify the source of their wickedness, the conditions under which double taxation is more and less problematic, and related fiscal settings where similar problems arise. This lecture will critically examine this growing international problem while forestalling despair by exploring potential solutions.
Chair: David Linke (KPMG)
- James Hines Jr (University of Michigan)
Session 4: Tax and Artificial Intelligence
15:00 - 15:45
Artificial Intelligence is a transformative technology that is likely to change business taxation in profound ways. This session explores three distinct dimensions of this change: How will unprecedented growth in data, computing power and generative AI models shape tax compliance and tax administration in the coming years? How will the delegation of decision-making to AI models affect the suitability of substantive transfer pricing law? With labour markets thoroughly disrupted by AI, do we need to fundamentally redesign tax systems in response, for instance by introducing new taxes on robots, tokens, or AI-generated rents?
Chair: Emma Agyemang (formerly Financial Times)
- Conrad Young (Oxford Internet Institute)
- Anniek van Elzelingen (Oxford University Centre for Business Taxation)
15:45 - 16:15 - Coffee Break
Session 4: Tax and Artificial Intelligence (cont.)
16:15 - 17:30
Chair: Emma Agyemang (formerly Financial Times)
- Stephen Bonovich and Jason Yen (Open AI)
- Niels Johannesen (Oxford University Centre for Business Taxation)
- James Hines Jr (University of Michigan)
17:30 - 18:30 - Conference drinks and reception
