Pillar II

Arm's Length, DEBRA, Deduction, Digital services tax, Intertax, Pillar II, Tax Theory, Unitary Taxation

(General Editor of Intertax)/ /Leave a comment

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber & Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the…

Pillar II

(Acquisition Manager, Wolters Kluwer, Legal & Regulatory, International Group)/ /Leave a comment

Welcome to the latest tax podcast in the International Law Talk  series. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer International Tax Blog, we will…

Intertax, Pillar II

(General Editor of Intertax)/ /Leave a comment

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Victoria Perry, Pillar 2, Tax Competition, and Low Income Sub-Saharan African Countries This article explores the implications of Pillar 2 of the G20/OECD Inclusive Framework Blueprint for global tax reform on tax incentives and…

GloBE, Pillar II, UTPR

(Squire Patton Boggs)/ /1 Comment

By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021.  No public consultation was undertaken regarding any draft Model Rules, as there was a need for speed in light of the tight timeline for implementation of Pillar Two’s 15% global minimum tax that had been agreed…

GloBE, IIR, Pillar II

(PhD by the Vienna University of Economics and Business and Tax Associate in Sao Paulo) and (Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)/ /Leave a comment

1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a fundamental overhaul of the international tax system as we know it. As time passes, the international community has time to digest these possible…

Enhanced cooperation, EU, Pillar II

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff) and (Loyens & Loeff )/ /Leave a comment

The current state of play in the negotiations for an EU Pillar 2 Directive is that all but one Member State are on board. Hence, there is one “dissenting” Member State left. As unanimity is needed within the Council to adopt an EU Directive on Pillar 2, it is currently not possible to implement Pillar…

IIR, OECD, Pillar II, UTPR

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam)/ /Leave a comment

Prof.M.F. (Maarten) de Wilde[1] Summary Yesterday, on 14 March 2022, the OECD published the Commentary on the Pillar 2 Model Rules, the global minimum rate for large multinationals. When reading the first pages, the author was overwhelmed by the urge to write this opinion and, ‘equally, however’, to make a connection with an animal farm….

Latin America, Pillar I, Pillar II

(Bomchil)/ /2 Comments

Abridged comments for a regional appraisal and possible outcomes to implementation 2010-2020: A Decade of Profound Changes in International Taxation Following the world financial crisis, the industrialized countries were deeply dissatisfied with revenue collection levels. In that context, which extended to the first years of the last decade, the political dialectic of the time left…

OECD, Pillar II

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam)/ /1 Comment

Prof.dr. M.F. (Maarten) de Wilde[1] Summary On 20 December 2021, the OECD published the announced Pillar Two Model Rules, as part of the envisaged establishment of a global 15% minimum level of company taxation for large multinationals (Pillar 2). No mechanism has been considered to provide for a parallel adaptation of countries’ tax treaty networks…

Europe, G20, Global minimum tax, OECD, Pillar II

(University of Muenster)/ /Leave a comment

Just two weeks ago on 8 October 2021, 136 of 140 member countries of the OECD/G20 Inclusive Framework agreed on a global tax deal that also features the GloBE international effective minimum tax (the so-called Pillar 2 of their work program). The G20 finance ministers backed the deal in their subsequent meeting, too. The agreement…

DST, EU law, GILTI, Made in America Tax Plan, Pillar I, Pillar II, United States

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)/ /Leave a comment

Raffaele Russo[1] “In those countries where income taxes are lower than in the United States, the ability to defer the payment of U.S. tax by retaining income in the subsidiary companies provides a tax advantage for companies operating through overseas subsidiaries that is not available to companies operating solely in the United States… The undesirability…

Effective Tax Rate, GILTI, IIR, OECD, Pillar II, United States

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Welcome to the second tax post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer Tax Blog, we will…

BEPS, MNEs, OECD, Pillar II, Transfer Pricing

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam)/ /Leave a comment

Summary There might be a leak in the OECD’s global minimum tax proposals (GLOBE; Pillar Two). To address the remaining challenges of base erosion and profit shifting (BEPS) by large multinational enterprises the OECD envisages a global minimum level of company taxation and top-up taxation by countries up to that level where other countries do…

Digital economy, EU law, EU/EEA, Fixed establishment, MNE Profits, MNEs, OECD, Pillar I, Pillar II

, , (Loyens & Loeff, Netherlands)/ /Leave a comment

In part 1 of this blog, we focused on the increased involvement of platforms in the levy of direct and indirect taxes. In this blog, we will highlight other digital economy tax trends, such as the shift of taxation rights on digital activities and fixed establishments. Shift of taxation rights between jurisdictions More user-and-consumer based…