Cross-border Tax Talks

Pillar Two: Hindsight is 20/24

Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC’s EMEA’s International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

Timestamps:

• 1:25 - How long have you been a tax practitioner and how has international tax changed over the years?
• 5:30 - Where are we today as Pillar Two begins to be implemented across the world? 
• 9:00 - Diversions and variances from the original intent of Pillar Two
• 12:00 - Do countries understand what they are signing up for? How are different countries going to administer Pillar Two considering the complexity?  
• 16:25 - What challenges are taxpayers seeing from the OECD’s December Administrative Guidance? 
  • 17:00 - Qualifying country-by-country reports
  • 20:30 - Hybrid arbitrage arrangements
• 25:45 -  What issues taxpayers should be mindful of in the Deals context?
• 32:15 - How applicable are the GloBE reorganization rules to common tax-free transactions?
• 36:20 - What are the issues around the allocation of deferred taxes?
• 41:10 - Any other issues taxpayers should be keeping an eye on moving forward? 
• 44:00 - Calum’s view on what happens in 2025 when the UTPR and several DSTs come into effect.

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