Cross-border Tax Talks

UK Updates: Pillar Two is Coming

Doug McHoney, PwC’s International Tax Services Global Leader, is in Barcelona, Spain at PwC’s Global Tax Symposium. On this episode, Doug is joined by Matt Ryan, a UK-based International Tax Partner with PwC. Doug and Matt discuss the UK’s parliamentary process, Liz Truss’s resignation, the corporate tax proposed changes, and Pillar Two, including a qualified domestic minimum tax, the income inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.

Timestamps:

• 1:00 - For those baffled by the UK’s parliamentary process, how is a Prime Minister elected?
• 5:30 - The new Prime Minister and Chancellor of Exchequer recently proposed significant changes to UK corporate taxation. What are those proposed changes?
• 8:00 - Where does the UK currently stand with enacting Pillar Two?
• 11:30 - Do you expect the UK to be the first country to move forward with enacting Pillar Two?
• 13:30 - How does the UK consultation process work when finalizing legislation?
• 17:50 - There are a lot of questions and uncertainties surrounding the implementation framework of Pillar Two. Let’s touch on a few of those:
  • 18:00 - Asset transfers, particularly regarding consolidated groups
  • 21:40 - Deferred taxes, particularly local accounts and consolidated accounts
  • 24:00 - Year-end adjustments
• 28:50 - What has been the biggest hurdle or challenge for clients as they assess the impact of Pillar Two? Is it systems and data?

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