Two weeks to 15 April 2022
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
OECD Pillar 2
Pillar 2 (P2) will establish a global minimum tax regime which will apply to both public and privately held multinational groups with consolidated revenue over €750m. With these rules proposed to apply in the UK to accounting periods ending on or after 1 April 2023, UK taxpayers have a very short window to prepare and get on top of what’s required to comply. See our latest resources and insights:
- Pillar 2: A pathway forward
As overwhelming as the OECD's Pillar 2 rules may seem, adoption can be managed effectively with planning and a roadmap outlining what your organisation needs to do to be ready. Exploring how new requirements interact with existing processes, data and technology will provide the strategic framework needed to embed Pillar 2 as just another obligation of the tax function. Read more in this item from two of our specialists. - Pillar 2: Deceptively complex?
The concept underlying Pillar 2 is relatively straightforward; a globally consistent 15% minimum tax regime. The reality is one of the most complex international tax measures ever implemented. Some of the complexity is driven by the challenge of homogenising long established domestic tax regimes, but some is driven by design and policy. See this article, by Rob Hines. - Client conversation themes - private equity clients
See this LinkedIn post from Gareth Hughes highlighting some important themes coming out of his recent discussions with private equity clients. - CIOT responds to UK implementation proposals
Further to our own response to the consultation, shared in our last edition, see the CIOT’s response here.
See further material on the OECD proposals in the OECD section below, including:
- Client webcast: Latest guidance on global minimum tax (Pillar 2)
Where have we reached in this process? What uncertainties remain? And what reactions are we seeing? Members of our Global Tax Policy team and subject specialists are coming together on Friday 29 April at 2.30pm BST to discuss just that. You can register your attendance here.
Corporate redomiciliation consultation - update
The Government has published a summary of the responses it has received to the recent consultation on corporate redomiciliation. The welcome news is that the Government has stated that it does indeed intend to introduce a redomiciliation regime. However, it added that more detailed analysis and engagement is needed before the necessary legislation can be enacted, but did not give any indication of the time they anticipate that process taking.
Case law update
- Tax consequences need to be taken into account when drafting legal documentation
In McEnroe & Anor [2022] TC 08444, the appellants sold the business (KCPL) in which they were each 50% shareholders for consideration stated in the sale and purchase agreement to be £8m. At the time of the sale, KCPL owned c.£1.1m to the Allied Irish Bank (the Bank Debt). The appellants submitted tax returns showing (total) consideration for the sale of KCPL as c.£6.9m (£8m less the Bank Debt) plus an earn-out received later. HMRC enquired into the returns and issued closure notices increasing the consideration to £8m (plus the earn out). The FTT held that where a contract is unambiguous as to the sale/purchase consideration there can be no apportionment under s52(4) TCGA 1992. The decision, whilst not unexpected, reinforces the importance of ensuring that legal documents are carefully drafted with a view to its tax consequences.
HMRC update double taxation treaty passport scheme register
On 8 April 2022, HMRC released an updated double taxation treaty passport scheme register with two amendments having been made. View the updated guidance here.
Uncertain Tax Treatment: The future of taxpayer engagement with tax authorities
The new notification of Uncertain Tax Treatment (“UTT”) regime became live on 1 April 2022. Businesses with UK turnover exceeding £200m and/or a £2bn UK balance sheet are within scope and corporation tax, VAT and PAYE (including NICs) are the covered taxes. Businesses in scope should review the potential impact of the regime (including on their HMRC relationship) and take any action that the review might necessitate, but the UTT legislation and manual also have a wider interest, beyond those immediately affected by the rules. Early engagement and transparency by taxpayers are key elements of the rules and they signpost a future where the onus will increasingly be on the taxpayer to disclose issues (for those who don’t do so today) and the nature of what “good” disclosures will look like will change significantly. Our specialists share their insights into the future of taxpayer engagement with tax authorities here.
Government sets out plan to make UK a global cryptoasset technology hub
The government has announced moves that will see stablecoins recognised as a valid form of payment as part of wider plans to make Britain a global hub for cryptoasset technology and investment. Read more in this press release
HMRC updates list of approved offshore reporting funds
HMRC has updated its list of approved offshore reporting funds to include the latest funds that have entered the Reporting Fund Regime.
EU
EU consultation on withholding taxes – new EU system to avoid double taxation
The European Commission has launched a consultation on a new EU-wide system for withholding taxes. Input received will feed into the upcoming legislative initiative planned for adoption in Q4 of 2022, which aims to introduce a common EU-wide system for withholding tax on dividend and/or interest payments. The draft legislation aims to remove barriers to cross-border investment and will also include a system for the exchange of information between tax authorities. The consultation closes on 26 June.
ATAD 3 - PwC comments on proposal for a Directive to prevent the misuse of shell entities and arrangements for tax purposes
PwC has submitted comments on the proposals, see here.
Tax compliance costs for SMEs
In a recent report by the European Commission’s Directorate General for Internal Market, Industry, Entrepreneurship and SMEs as a follow-up to a 2018 study, it found that smaller enterprises faced a disproportionately higher burden of tax compliance than larger enterprises, mostly through data collection obligations, preparation, and review.
CFE Tax Advisers Europe
- CFE issues opinion statement on EU Proposal for global minimum taxation
The Confédération Fiscale Européenne (CFE) has published an Opinion Statement on the EU proposal for a Directive on minimum tax and OECD Model Rules implementing Pillar 2 (Global Minimum Taxation). - EU Tax Policy News Top 5
The latest round-up of EU Tax Policy news from the Confédération Fiscale Européenne (CFE). The latest edition includes: 1) ECOFIN: Poland vetos Pillar 2 minimum tax implementing proposal; 2) AG Opinion in Belgian DAC6 Legal Privilege Challenge Case: C-694/20 Orde van Vlaamse Balies; 3) Register now: CFE Forum 2022 on 12 May 2022 in Brussels; 4) OECD Consultation on Draft Model Rules for Domestic Legislation on Scope & Global Minimum Tax Implementation Framework Consultation; and 5) Forum on Tax Administration: Inventory of Tax Technology Initiatives. Visit their latest news page here. - Global Tax Top 10
The March edition includes: 1) Pillar 2 Directive: Poland and Estonia maintain veto ahead of ECOFIN Council meeting; 2) OECD: Globe Model Rules update & guidance; 3) EU Agreement on carbon border adjustment mechanism; 4) Registration open: CFE Forum 2022 on 12 May 2022 in Brussels; 5) EU reviews tax blacklist; 6) EU to extend VAT reverse charge mechanism; 7) OECD: public consultation on crypto-assets; 8) OECD transfer pricing country profiles updated; 9) New FATF anti-money laundering standards; and 10) Review of EU economic governance framework.
OECD
Pillar 2
- Client webcast: Latest guidance on global minimum tax (Pillar 2)
Where have we reached in this process? What uncertainties remain? And what reactions are we seeing? Members of our Global Tax Policy team and subject specialists are coming together on Friday 29 April at 2.30pm BST to discuss just that. You can register their attendance here. - Public consultation meeting on the Implementation Framework of the global minimum tax
The public consultation meeting will take place virtually on Monday 25 April. This follows the call for input on the Pillar Two Implementation Framework which closed for comments on 11 April. The event will be recorded for replay. - Public comments received on the Implementation Framework of the global minimum tax
The OECD/G20 Inclusive Framework on BEPS released further technical guidance on the 15% global minimum tax agreed in October 2021 and launched a public consultation. The OECD has now published the public comments received. View our response here. - CIOT responds to OECD Pillar 2 consultation
The Chartered Institute of Taxation (CIOT) has published its response to the OECD's Pillar 2 Consultation on Implementation. You can read it here.
Pillar One Model Rules
- OECD invites public input on extractives exclusion under Amount A of Pillar One
As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments until 29 April on the Extractives Exclusion under Amount A of Pillar One. - OECD invites public input on draft rules for scope under Amount A of Pillar One
The OECD is currently seeking public comments on the Draft Model Rules for Domestic Legislation on Scope (but not yet the exclusions for Regulated Financial Services nor Extractives) under Amount A of Pillar One, the third item in the rolling agenda of Pillar One building blocks. See our Tax Policy Alert on this latest OECD consultation in the rolling agenda on Pillar 1 building blocks. See our Tax Policy Alert
New tool provides insights into digitalisation practices and initiatives for 76 tax administrations
The OECD Forum on Tax Administration and eight key partner organisations launched a new global inventory of tax technology initiatives containing information on the use of leading technology tools and digitalisation solutions implemented by 76 tax administrations across the world. Read more in this OECD item.
Making tax dispute resolution more effective: New peer review assessments released
Under BEPS Action 14, jurisdictions have committed to implement a minimum standard to improve the resolution of tax-related disputes between jurisdictions. Despite the significant disruption caused by the ongoing COVID-19 pandemic and the necessity to hold all meetings virtually, work has continued with the release of the Stage 2 peer review monitoring reports for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco and Tunisia. See this OECD item.
Other territories
International
Taxation of the digital economy
Keep track of the number of international initiatives that are underway to address the tax problems caused by digitalisation of our economy:
- OECD Pillars 2
See comments in OECD section above. - EU Pillar 2 Directive
See comments in EU section above. - Digital tax byte
The latest edition from 14 April includes an OECD release on the IT format for sharing digital platform reporting information and an update on the EU attempts to adopt a Directive to implement Pillar Two. - Digital tax megabyte - March 2022
This edition includes publication of the Commentary on Pillar 2 GloBE Rules together with the status of attempts to implement those rules across the EU and also in Switzerland. We focus too, on the consultation on the Implementation Framework for the GloBE Rules and on a possible extension of the EU's blacklist criteria for non-cooperative jurisdictions regarding Pillar 2.
Environmental, Social and Governance (ESG)
- UK Plastic Packaging Tax - are you ready?
The UK Government introduced a new tax on plastic packaging from 1 April 2022 and the first registrations are due by 30 April 2022. Whether you manufacture plastic packaging or import packaged goods, the UK's Plastic Packaging Tax could have implications for you. Find out more about the tax on our webpage here. - ESG & Tax - Sustainability & Transformation
The second of our ESG & Tax virtual webinars took place on Tuesday 5 April, with the focus on the key role tax plays as part of the Business Sustainability and Transformation agenda. View the recording here.
Australia
Review of R&D Tax Incentive Dual Agency Administration Model
In early 2021, the Federal Government announced the Board of Taxation would undertake a review to evaluate the dual‑agency administration model for the R&D Tax Incentive (R&DTI). The report was completed in November 2021. On 29 March 2022, the Government announced the publication of the Report and noted that the Board’s report provides valuable insights into ways to further enhance the administration of the R&DTI program. Read more in this PwC alert.
Austria
Rising energy costs: Reduction prepayments of individual and corporate income tax
Austrian companies currently face rising energy costs, which may also impact their liquidity in the short term. For this reason, the Austrian Ministry of Finance announced on 1 April 2022 that it will be possible to simplify and reduce prepayments of individual and corporate income tax in administrative terms. The taxpayer must be able to credibly demonstrate that the increase in energy costs has a significant economic impact. Read more in this PwC news item.
Attractive cybersecurity subsidy for SMEs
From 1 April 2022, Austrian SMEs will be eligible to receive an attractive cybersecurity subsidy in the form of a non-repayable grant for investments of up to EUR 50,000. Read more in this PwC tax news item.
Belgium
See here for latest updates.
Belgium & Netherlands to terminate cross-border workers deal from 1 July 2022
The Belgian and Dutch competent authorities on March 31 signed an agreement stating that the mutual agreement on the tax status of cross-border workers who work from home during the coronavirus pandemic will expire 1 July 2022, according to information published April 6 in the Dutch official gazette. See this PwC news item.
New provisions grant judicial police powers to Belgian tax inspectors to combat fraud
The law of 17 March 2022 regarding various fiscal provisions to combat fraud has recently been published and adopted. It includes new tax provisions that remove the existing legal obstacles for officials of the Belgian tax administration to participate in judicial investigations. Read more in this PwC news item.
Canada
Canadian Government releases 2022 federal budget
The Deputy Prime Minister and Minister of Finance, Chrystia Freeland, presented the government’s budget on 7 April. The budget does not include changes to corporate income tax rates, nor an update on the expected timing of ‘anti-hybrid’ legislation, but does include a number of corporate and international proposals including the announcement of a public consultation on the Canadian implementation of Pillar Two, along with domestic minimum top-up tax. The government stated that the primary charging rule and domestic minimum top-up tax would be effective in 2023, with the secondary charging rule effective not before 2024. Read more in this PwC Tax Insights.
Chile
Proposed reservations to pending US-Chile Treaty: action in the stalled treaty ratification process
Ratification of the pending US-Chile Treaty, along with other pending treaties, has been stalled — most recently, due to a potential conflict between certain provisions of US tax law enacted in 2017 and the nondiscrimination article and/or other articles of the treaty. Following recent input from the business community, the Senate Foreign Relations Committee considered the pending treaty at a hearing, and on 29 March 2022, approved it for full Senate consideration, with certain reservations. If ultimately approved by the Senate, the reservations would require the approval of Chile in order for the treaty to progress toward ratification. Read more in this PwC Tax Insights.
Germany
Tax & Legal News – Issue Q1, April 2022
Read our newsletter for the first quarter of 2022 covering Tax Court cases, Official Pronouncements and related news from Europe.
Hong Kong
The limited activities in Hong Kong are considered crucial in determining the source of trading profits
In a recently published Board of Review Case D14/20, the Board held that the trading profits derived by a Hong Kong company (the taxpayer) were chargeable to Hong Kong profits tax despite only limited activities performed by the taxpayer in Hong Kong. In this case, whilst both the purchase and sale contracts of the taxpayer were negotiated, concluded and executed outside Hong Kong, the Board focused on the activities carried out by the taxpayer in Hong Kong as well as the purpose of the taxpayer's establishment in Hong Kong in determining whether the taxpayer was carrying on a trade or business in Hong Kong, and if so, whether the profits of that trade or business also arose in or were derived from Hong Kong. Read more in this PwC news flash.
The Inland Revenue Department's Taxonomy Package
Following a series of consultations with various parties and stakeholders in late 2021, on 31 March 2022, the Inland Revenue Department announced the latest updates of its project on electronic filing of profits tax returns. Read more in this PwC news flash.
Impact of BEPS 2.0 Pillar Two on international shipping business
The OECD’s Pillar Two Global Anti-Base Erosion (GloBE) Model Rules provide an exclusion of international shipping income and qualified ancillary international shipping income. Shipping groups with establishments in Hong Kong should take action now to assess the potential impact of the GloBE Rules on their different streams of income and whether their commercial substance is aligned with shipping income derived in Hong Kong. Read more in this PwC news flash.
Hong Kong's proposed tax concession for family-owned investment holding vehicles
Following the announcement by the Financial Secretary in Hong Kong's 2022/2023 Budget in February 2022, the HKSAR Government has recently launched a consultation on a proposal to provide tax concession for family-owned investment holding vehicles (FIHVs) managed by single family offices (SFOs) in Hong Kong. Read more in this PwC news flash.
India
Finance Bill 2022 enacted
The Finance Bill 2022 (Amended Bill) was passed by the Lok Sabha on 25 March 2022 with amendments to the original Bill that was tabled before the Lok Sabha on 1 February 2022. Subsequently, the Bill was affirmed by the Rajya Sabha without any further amendments and has now been enacted. Read more in this PwC news alert.
Supreme Court upholds validity of assessment order in name of an amalgamating entity
The Supreme Court has categorically held that the validity of an assessment order with respect to an amalgamating company cannot be determined on a bare application of dissolution or winding up provisions of the Companies Act 2013, but that it would depend on the terms of the amalgamation and the facts of each case. Read more in this PwC alert.
Ireland
EU mandatory disclosure of reportable cross-border arrangements
As noted above, the Irish Revenue Commissioners have issued Revenue eBrief No. 078/22, updating guidance on the EU mandatory disclosure of reportable cross-border arrangements (DAC6) to reflect changes introduced by Finance Act 2021 and to provide additional guidance on the various hallmarks, filing obligations, nexus and the main benefit test.
Kenya
Kenya releases 2022 Budget
In its recent Budget, the Kenyan Government announced various changes to the country's value-added tax regime, confirmed plans for country-by-country reporting requirements, and announced new rules requiring payment of disputed tax pending the outcome of a taxpayer's appeal. Further, the Budget announces that the Income Tax Act will be amended to exclude microfinance institutions licensed under the Microfinance Act from the interest expense deduction limitation rules, introduced in response to the OECD's tax base erosion and profit shifting (BEPS) Action Plan. See our Budget bulletin.
Korea
Korean Tax Update - April 2022
This edition includes: 1) MOEF plans to include the global minimum tax in the tax reform proposals for 2022; 2) due date for payment of corporate local income tax extended by three months to 31 July 2022 for SMEs affected by COVID-19; 3) NTS audit manual is amended; 4) Korea’s tax expenditure plan for 2022 was approved; and 5) rulings update.
Luxembourg
FATCA/CRS reporting : Updated FATCA schema is expected for April 2022
The Luxembourg tax authorities recently announced some changes in the way Passive Non-Financial Foreign Entities (“NFFEs”) with US Controlling Persons are reported under FATCA. Read more in this PwC news item.
Malaysia
Exemption of foreign-sourced income from Cukai Makmur
The Income Tax (Exemption) Order 2022 was gazetted on 5 April 2022 to provide exemption from Cukai Makmur on the foreign-sourced income received in Malaysia. The Exemption order is effective for the year of assessment 2022. Read more in this PwC alert.
Middle East
Oman: Amendments to the Executive Regulations of the Foreign Capital Investment Law
A new Ministerial Decision was issued recently by the Ministry of Commerce, Industry, and Investment Promotion to amend certain Articles of Executive Regulations of the Foreign Capital Investment Law (“FCIL ER”), which became effective from 4 April 2022. We believe that these amendments were introduced to further improve the legislative framework of the FCIL in a way that enables and enhances potential foreign investment opportunities to arise and prosper. This news alert intends to highlight some of the key features of the amended provisions of the FCIL ER.
UAE: Whistleblower program for tax violations and evasion
The UAE Federal Tax Authority “FTA” has released a new User Guide introducing a whistleblower system for violations and tax evasion (referred to as “Raqeeb”) to receive and process leads relating to the non-compliance of natural or legal persons with the tax legislation, as well as to offer a monetary reward to informants when certain conditions are met. The User Guide is available on the FTA portal and includes information on how to submit an application to the whistleblowing online process. Read more in this PwC news alert.
Netherlands
COVID and working cross-border - update
The mutual agreements the Netherlands has with Belgium and Germany have again been extended up until 30 June 2022. In the official publications regardings the extensions, it was mentioned that this would be the final extension for both agreements. See this PwC news item.
New Zealand
Tax Tips Alert: 39% tax rate integrity measures
On Wednesday 16 March, the Government released a discussion document for consultation, with significant proposals that will impact thousands of taxpayers across New Zealand, including shareholders in companies and any individuals who operate small service businesses. The discussion document states that the motivation of the proposals is to ensure the 39% personal tax rate increase is effective in raising additional tax revenue, by reducing the circumstances where a taxpayer is able to avoid the new 39% personal income tax rate by diverting income through entities that are taxed at a lower rate. Read more in this PwC alert.
Norway
The S of ESG - Doing business in Norway going forward
The Transparency Act comes into force in Norway 1 July 2022. All Norwegian enterprises and foreign enterprises doing business in Norway will now become obliged to not only run their business ESG-compliant, but also to assess their own compliance, in order to secure human rights and labour rights within its entire supply chain. Read more in this PwC blog.
South Africa
PwC Synopsis - March 2022
This edition includes: 1) The revenue (as opposed to capital) nature of ‘other finance’ charges – a plausible argument; 2) Challenging South African Revenue Service (SARS) judgment debt; and 3) SARS watch.
Switzerland
IMF says Switzerland well placed to respond to tax challenges
In its newly released Article IV consultation, the International Monetary Fund has said Switzerland faces a number of fiscal policy challenges but may benefit from the OECD's international tax reform plans. Read more in this IMF news release.
For the latest updates on current topics, see this PwC Switzerland Insights page.
Thailand
Losses can be deducted against gains from transfer of cryptocurrencies or digital tokens
Gains from the transfer of cryptocurrencies or digital tokens which exceed the cost of investment have been treated as assessable income under Section 40(4)(i) of the Revenue Code since 14 May 2018. See this PwC Tax Insight.
Turkey
New tax measures law published
Law number 7394, increasing the corporate tax rate on the income of companies in the financial services sector to 25%, was published in the Official Gazette on 15 April 2022. Other tax measures under this law include exclusion of capital replenishment funds from the corporate income tax base, broadening the scope of the tax exemption related to income from investment funds, restriction of the tax deductibility of advertising expenditures received from providers that have been banned under social media law, reinforcement of the VAT incentives in manufacturing and tourism, relaxation of the holding period condition for VAT exemption related to real estate purchases by non-residents, and amendments to tax fraud related provisions of the tax procedural code. Read more in this PwC tax bulletin.
US
Treasury releases ‘FY23 Green Book’ describing President Biden’s tax proposals for businesses
As reported previously, President Biden has sent to Congress a $5.8 trillion FY 2023 budget that proposes new business tax increase proposals including an “undertaxed profits rule” that would replace the current base erosion anti-abuse tax (BEAT), a 28% corporate income tax rate and numerous other tax provisions that were included in his FY 2022 budget. This PwC Tax Insight covers the FY23 Budget proposals (and proposed effective dates) that are generally applicable to businesses.
Proposed reservations to pending US-Chile Treaty: action in the stalled treaty ratification process
Ratification of the pending US-Chile Treaty, along with other pending treaties, has been stalled — most recently, due to a potential conflict between certain provisions of US tax law enacted in 2017 and the nondiscrimination article and/or other articles of the treaty. Following recent input from the business community, the Senate Foreign Relations Committee considered the pending treaty at a hearing, and on 29 March 2022, approved it for full Senate consideration, with certain reservations. If ultimately approved by the Senate, the reservations would require the approval of Chile in order for the treaty to progress toward ratification. Read more in this PwC Tax Insights.
US APA report for 2021 shows steady overall results and increased interest in APA program
The IRS Advance Pricing and Mutual Agreement Program (APMA) has issued its 23rd Annual Statutory Report concerning Advance Pricing Agreements (APAs). The Report observes that during calendar year 2021, APMA completed almost the same number of APAs as those completed in 2020, without significant increase in processing times. Read more in this PwC Tax Insights.
California FTB provides service sourcing guidance
The Franchise Tax Board (FTB) recently issued a Legal Ruling that appears to indicate that the FTB is taking a look-through "customer's customer" approach for services that the FTB characterizes as being directed toward the customer's customers. This look-through may be broader than the previous "marketing service" approach. Read more in this PwC Tax Insights.
Colorado District Court invalidates 2019 Section 245A Temporary Regulations for procedural violations
On 4 April, the US District Court for the District of Colorado granted summary judgment to Liberty Global Inc. (LGI) in Liberty Global Inc. v. United States, ruling that the Section 245A temporary regulations (the Temporary Regulations) adopted by the Treasury Department on 18 June 2019, are invalid because they were issued without following the Administrative Procedure Act's (APA) notice and comment requirements. Companies should assess the impact of LGI on relevant positions. This nuanced analysis may differ depending on where the taxpayer is located and whether and when the taxpayer distributed earnings that were subject to the Temporary Regulations. The government is expected to appeal the decision. Read more in this PwC Tax Insights.
Kentucky enacts major sales tax base expansion, updates IRC conformity, and establishes tax amnesty
The Kentucky General Assembly on 13 April enacted H.B. 8 by overriding Governor Andy Beshear’s (D) veto, imposing sales and use tax on website design, development, and hosting services, marketing services, prewritten computer software access (SaaS), and numerous other services, effective 1 January 2023. The legislation also reduces the individual income tax rate beginning in 2023 depending on state revenue levels, updates IRC conformity, and establishes a limited tax amnesty program. Read more in this PwC Tax Insights.
New York budget bill includes significant changes related to pass-through entity tax; creates similar New York City tax
The New York Governor recently signed tax legislation as part of the state’s FY23 budget. The legislation amends the state’s pass-through entity tax (PTET) by creating a new S corporation category for entities with all resident shareholders and excluding pass-through entity taxes from the definition of “income taxes” for purposes of the addback to state taxable income. Additionally, and of significant note for New York City (NYC) resident individuals, the legislation establishes a new Tax Law Article 24-B creating a NYC PTET. Read more in this PwC Tax Insights.
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- Tax Readiness: Supply Chain, Business Disruption, and Unlocking Cash through Tax
Register here to watch the replay of our webcast from 13 April, where our panel of specialists discuss the current global and economic environment and illustrate the challenges through various case studies to demonstrate how tax might offer some pathways to clarity and improved cash flow. - Cross-border tax talks: Spin the Globe: Macroeconomic and Geopolitical trends
In this episode from 6 April, Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. They discuss macroeconomic trends, the geopolitical landscape, the inflationary environment, trade wars, global/economic impacts on various sectors,and much more. - The Biden Budget: Build Back Better Again?
In this TaxNotes podcast PwC’s Rohit Kumar discusses the Biden administration’s fiscal 2023 budget, explaining the new proposals and how the budget is different than the Build Back Better Act. - Policy on Demand series
- Week in Review
- In this episode from 15 April, Drew Lyon shares his insights on the March inflation release and looks ahead to the guidance that companies include in their Q1 earnings releases for the rest of the year. He also answers the question that he received most this week: How does inflation impact Congressional interest in reviving Build Back Better legislation?
- All focus is on what’s next for US legislation and Pillars 1 & 2. In this episode from 8 April Pat Brown shares how his takeaways from this week have ties to the past, present, and future.
- How does Pillar 2 apply to deals?
Pillar 2 has some counterintuitive outcomes with respect to deals. In this episode from 28 March, Calum Dewar joins Wade Sutton to discuss issues to consider, approaches to diligence, and the impact on acquisitions and dispositions. - Challenges for business related to Pillars 1 & 2
There are still many unanswered questions despite additional guidance on Pillars 1 & 2. In this episode from 28 March, Pat Brown and Will Morris discuss the Pillar 2 commentary, what’s ahead for ECOFIN, and the status of Pillar 1. They also share why it is important to stay involved. - Tax Readiness: Exploring the details of the OECD Pillar Two Rules Commentary 30 March
As noted above, register here to watch the replay of our webcast from 30 March, where our panel of specialists discuss observations and insights into the recently released OECD Commentary to the Pillar Two Model Rules.
A back catalogue of previous webcasts and other resources are available on our US tax reform hub here.