OECD Pillar Two - An International Tax Update with Jonathan Schwarz

Introduction

Join international tax specialist barrister, Jonathan Schwarz of Temple Tax Chambers, who will explore the latest OECD developments on implementation of Pillar 2, which aims to ensure that multinational enterprises pay a global minimum level of tax (15%).

This pillar is intended to address the remaining base erosion and profit shifting issues of the OECD/G20 BEPS project.

It is proposed that Pillar Two will be brought into law in 2022, to be generally effective in 2023, with the UTPR coming into effect in 2024.

What You Will Learn

This webinar will cover the following:

• The Pillar Two elements
• Two domestic law rules
• An ‘income inclusion rule’ (IIR)
• An ‘undertaxed payments rule’ (UTPR)
• An international treaty‐based rule: a ‘subject to tax rule’ (STTR)
• Implementation
• Model rules
• A multilateral instrument
• An implementation framework
• GloBE Model rules -Key elements of the draft model rules
• Chapter 1 Scope
• Chapters 2-5 key operative rules
• Charging Provisions
• Computation of GloBE income or loss
• Computation of Adjusted Covered Taxes
• Computation of Effective Tax Rate and Top-up Tax
• Chapter 6 Mergers and acquisitions (Corporate Restructurings and Holding Structures)
• Chapter 7 Tax neutrality and distribution tax regimes
• Chapter 8 Administration
• Chapter 9 Transition rules
• Chapter 10 Definitions
• Conclusions and prospects

This webinar was recorded on 25th May 2022