Revisiting the Old, Facing the New: Problems and Opportunities in International Taxation
26 June 09:00 to 18:00
Saïd Business School, Oxford OX1 1HP
Some of the most pressing problems facing the international tax community have been around for years. The challenges arising from the digitalisation of the economy and how to address them have been discussed for over a decade – but with Pillar 1 now officially declared dead, we are no closer to a durable solution. Moreover, new problems are emerging. The Side-by-Side Package agreed in January 2026 may have introduced fresh instability into the Global Minimum Tax, double taxation is appearing in new domains such as the taxation of digital services, and Artificial Intelligence may be reshaping the economy so fundamentally that governments need to think of entirely new ways to raise revenue. Yet the picture is not wholly bleak. Just as there are old and new problems, new options are coming into view alongside old ones, not least because of the transformative impact of Artificial Intelligence.
This conference considers old and new problems, as well as old and new opportunities, in four areas.
Session 1
What comes after Pillar 1?
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.
Session 2
The Side-by-Side Package: where does it leave GloBE?
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?
Session 3
Tax and Artificial Intelligence
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?
Session 4
Wicked Double Taxation
Loughlin Hickey Annual Lecture delivered by Prof. James Hines Jr
Confirmed contributors include:
Silke Bruns (Federal Ministry of Finance, Germany)
Richard Collier (Oxford University Centre for Business Taxation)
Michael Devereux (Oxford University Centre for Business Taxation)
James Hines Jr (University of Michigan)
Niels Johannesen (Oxford University Centre for Business Taxation)
Giorgia Maffini (PwC)
Helen Miller (Institute for Fiscal Studies)
Pierce O’Reilly (OECD)
Wolfgang Schön (MPI, Munich)
Anniek van Elzelingen (Oxford University Centre for Business Taxation)
John Vella (Oxford University Centre for Business Taxation)
Jason Yen (Open AI)
Conrad Young (Oxford Internet Institute)
Emma Agyemang (formerly Financial Times)
Registration
This conference is open to all and in-person only. Please register by completing the registration form.
Contact
If you have any questions about this event, or would like to be added to our mailing list, please email cbt@sbs.ox.ac.uk.
