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Cross-border Tax Talks
November 15, 2023
Pillar Two Safe Harbors: The CbCR journey
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by David Ernick, a Principal with PwC’s Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department, at PwC’s Global Transfer Pricing Conference in San Diego, California. They discuss Country-by-country reporting (CbCR) transitional safe harbor rules, including the safe harbor tests, exclusions to the rules, the difference between the safe harbor rules and the full GLoBE rules, as well as whether a CbCR is ‘qualifying’. Doug and David also discuss the history and implementation of public CBCR.
Timestamps:
- 1:10 - A trip down memory lane to Boston University, David’s alma mater.
- 3:10 - What is country-by-country reporting and how did it start?
- 7:15 - Why did the OECD provide taxpayers with the transitional CbCR safe harbor rules? What are the general policy reasons?
- 9:10 - How does the transitional CbCR safe harbor work?
- 12:00 - What are the three tests to meet the transitional CbCR safe harbor ?
- 14:25 - Are there any specific differences between the full GloBE rules and the transitional CbCR safe harbor rules?
- 21:45 - What is a qualifying country-by-country report?
- 26:50 - What happens if there’s a mistake on the country-by-country report?
- 27:30 - What are some of the challenges associated with transfer pricing adjustments?
- 31:00 - What do taxpayers need to do to accelerate their internal country-by-country process? What kind of challenges do they face?
- 33:45 - What is public country-by-country reporting?
- 37:30 - When will the public CbCR directive be implemented?
- 39:10 - What immediate steps should listeners consider?
Speakers
International Tax Services Global Leader, PwC US
Principal, Transfer Pricing, PwC US
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