International Tax in Focus: From Policy to Practice Masterclass with Professor David Rosenbloom and Professor Dr René Matteotti
2 September 2026
How are international tax rules evolving—and what does this mean for the businesses, advisers and tax administrations navigating them?
These questions brought participants together for Tax Academy of Singapore’s three-day Masterclass with Professor David Rosenbloom, Professor Dr René Matteotti and guest speakers from government and practice. Across six sessions, the programme connected international tax policy with the practical challenges of interpreting rules, managing cross-border risks and resolving disputes.
Connecting policy, practice and perspectives
The Masterclass explored three interconnected themes: the direction of international tax policy, the application of transfer pricing and treaty rules, and the pursuit of greater tax certainty.
Professor Rosenbloom examined developments at the OECD and United Nations, Pillar Two and the challenges of international tax cooperation. His sessions also explored distinctive features of U.S. transfer pricing, including cost-sharing arrangements and the Coca-Cola case, before returning to wider issues shaping international taxation.
Professor Dr Matteotti and Mr Sam Sim brought comparative Swiss and Singapore perspectives to transfer pricing, examining developments after BEPS, significant cases and approaches to dispute resolution.
Mr Justin Jerzy Tan explored tax treaty foundations, anti-avoidance rules and the Multilateral Instrument, while Ms Ng Pei San examined mechanisms for achieving greater certainty, including Mutual Agreement Procedures, Advance Pricing Arrangements and mandatory arbitration.
Together, the sessions offered participants opportunities to question assumptions, compare approaches across jurisdictions and consider the practical implications of evolving international tax rules.
Bringing tax into the boardroom
Complementing the Masterclass, Tax Academy of Singapore and the Singapore Institute of Directors (SID) co-organised “Board’s Blindspot — Tax Strategy & Risks in a VUCA World”.
The seminar brought board members and tax professionals together to explore how tax intersects with business strategy, corporate governance and risk oversight—extending the conversation beyond technical interpretation to leadership and decision-making.
Explore the ideas: Perspectives & Insights
What shapes international tax policy? How are transfer pricing principles applied in practice? And how can cross-border disputes be prevented or resolved?
Our six-part Perspectives & Insights series draws together key themes from the Masterclass:
1. The Making of International Tax Policy
The tension between national taxing rights and international coordination, viewed through digitalisation, Pillar Two and dispute resolution.
Read Session 1 insights (opens in new tab)
2. Transfer Pricing
The evolution of transfer pricing after BEPS, with a focus on substance, financial transactions and dispute resolution.
Read Session 2 insights (opens in new tab)
3. The Arm’s-Length Method and Peculiarities of U.S. Transfer Pricing
U.S. transfer pricing rules, cost-sharing arrangements and lessons emerging from the Coca-Cola case.
Read Session 3 insights (opens in new tab)
4. Treaties – Foundations
How tax treaties operate alongside anti-avoidance measures and BEPS implementation, with implications for cross-border investment.
Read Session 4 insights (opens in new tab)
5. Treaties – Advanced Topics
Mechanisms for resolving cross-border tax disputes and strengthening certainty for taxpayers and tax administrations.
Read Session 5 insights (opens in new tab)
6. Major Current International Tax Issues
Current challenges in international taxation, including arbitration, Advance Pricing Arrangements and approaches to dispute resolution.
Read Session 6 insights (opens in new tab)
Tax Academy of Singapore thanks Professor David Rosenbloom, Professor Dr René Matteotti, our guest speakers and all participants for contributing their expertise, questions and perspectives to three days of learning and exchange.