International tax update for multinationals operating in the UK - period to 28 May 2021

Two weeks to 28 May 2021

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.

UK

Responding to the business impacts of COVID-19
Visit our global crisis centre webpage and our COVID-19 hub on TheSuite to continue to keep up to date with developments on this topic.  Of particular relevance to multinational companies operating in the UK, navigate the global tax, legal and economic measures in response to COVID-19 by territory here. In relation to the UK:

• The post-pandemic world of work: can you let employees work from anywhere?
  According to a number of recent surveys, almost half of UK employees would like to work from abroad when travel restrictions are lifted. With office-based staff having worked from home successfully for over a year, many now feel that they could do their job just as well from a home in another country. In addition, some companies have closed their offices and introduced permanent work-from-home positions, meaning there may be no business need to be based in the UK. If productivity and performance are not an issue, is there any reason why employers shouldn’t let staff swap Basingstoke for the Bahamas or Milton Keynes for Marbella? We discuss some of the issues employers should consider when dealing with such requests here.
• The rise of hybrid working: How to transform your organisation for our changed world
  Business leaders are facing a challenge no leader has faced before. The way we live, work and interact has been changed forever by the pandemic, the behaviours it has engendered and the trends it has accelerated. It’s not an issue for HR, IT or operations to deal with in isolation. This must start at the top, because success depends upon being able to view the whole landscape, recognise the complex and intricate ways in which everything connects and unite the organisation behind a clear strategy. Read more in this PwC Insight. 

Notifying HMRC of an uncertain tax treatment
From May 2022, large businesses (corporates and partnerships) will be required to send a specific notification to HMRC if their tax returns contain an Uncertain Tax Treatment (‘UTT’). This new obligation will apply to the legal interpretation of Corporation Tax, Income Tax (including PAYE) and Value Added Tax legislation, for returns that are due to be filed with HMRC after April 2022 and the tax amount involved is more than £5m. This new obligation is the subject of current HMRC consultation, and draft legislation is expected in Summer 2021.  However, for corporation tax purposes, any accounting period that started after 2 May 2020 and ends on or after 1 May 2021 may be subject to this new regime.  Transactions that have already taken place, or are planned in the next few months, will need to be considered in light of this new obligation.  Read this flyer for more information.

Double tax relief (DTR)

• Aozora - FTT concludes LoB clause is not an ‘express provision’ denying credit relief
  The First-tier Tax Tribunal (FTT) has allowed the taxpayer’s appeal in Aozora GMAC Investments (Aozora) v HMRC, ruling that the Limitation of Benefits clause in the US-UK double tax treaty is not an ‘express provision’ that relief by way of credit is not to be given under the treaty and therefore that it does not prohibit Aozora from claiming unilateral credit relief in the UK.  Taxpayers considering whether they are entitled to credit relief in the UK for tax that is not relieved by an applicable double tax treaty should consider the potential implications of this ruling for their own arrangements and seek advice where necessary.  See more here.
• Double Taxation Treaty Passport Scheme register
  HMRC has updated the double taxation treaty passport scheme register which shows details of companies registered for the scheme, with 45 additions and four amendments. 

HMRC introduces new Application Programming Interface for  corporate interest restriction returns
HMRC has developed an Application Programming Interface (API) for submitting Interest Restriction Returns (IRR) and for reporting company appointments and revocations. This will be available for use from June 2021. The existing service will run in parallel with the API until April 2022, at which time HMRC will be looking to mandate the use of API for submission of IRRs and reporting company appointments and revocations. Read more in this HMRC blog.

UK and Spain meet for first time on Gibraltar tax matters
The UK and Spain recently held their first meeting under a new mechanism intended to foster cooperation between authorities in Spain and Gibraltar. The International Agreement on Taxation and the Protection of Financial Interests between the UK and Spain regarding Gibraltar entered into force on 4 March 2021. The treaty is intended to improve tax cooperation and exchange of information between the tax authorities of Spain and Gibraltar and sets out rules and mechanisms for resolving conflicts over tax residency. Read more in this Government press release.

HMRC consults on draft regulations: DOTAS, DASVOIT and POTAS regimes
HMRC has launched a consultation on draft regulations to ensure that HMRC can act decisively where promoters fail to provide information on their avoidance schemes and make taxpayers aware at an earlier stage where it suspects an avoidance scheme is being sold. The consultation closes on 13 June 2021.

OTS Capital Gains Tax Review: Simplifying practical, technical and administrative issues
The Office of Tax Simplification (OTS) has published its second report as part of its Capital Gains Tax Review which considers a range of key practical, technical and administrative Capital Gains Tax issues. See this brief note, prepared by Tim Hughes for the Deals team, which gives an overview of its contents and next steps.

Tax Accounting Insights webex - 9 June 2021
The next webex in our tax accounting insight series is being held on Wednesday 9 June - see this link to register. We’ll discuss the BEIS UK corporate governance proposals and in particular the proposed “internal controls statement” (UK SOX) requirement. We’ll explore the different options for the new regime as well as our experience of the "no regrets" actions organisations are considering now, to stand up a robust internal controls process over financial reporting that is documented and monitored. In our experience tax was one of the most common areas of material weakness when the US regime was introduced and so it will be hugely important for Tax professionals to get this right, with the correct level of support from the wider organisation.

Brexit & other international trade developments
The UK has left the EU and negotiations on the future trading relationship of the UK and the EU have concluded with a deal agreed. So what next for businesses as we enter this new trading world?

• Brexit and EU law rights
  Peter Halford and Mark Whitehouse have written this article on the impact of Brexit on EU law rights for the Tax Journal, which focuses on the implications for direct tax cases. For copyright reasons, we’re currently only able to share a link to the item on Tax Journal’s website, a pdf of the article will be shared in our next edition.

Visit our Beyond Brexit webpage for the latest updates.

Case law round-up

• Supreme Court decision on the Tooth discovery case
  The Supreme Court  has handed down its decision in the long-running dispute between HMRC and Raymond Tooth. It deals with several important points relevant to HMRC’s ability to issue assessments or penalties on the basis that a taxpayer has “deliberately” submitted an incorrect return to HMRC.  It also definitively addresses the concept of a discovery assessment becoming ‘stale’, which had become orthodox thinking in recent years. Read more in this PwC Suite item.
• Supreme Court applies a Ramsay analysis in a business rates case - Hurstwood Properties v Rossendale Borough Council [2021] UKSC 16
  In this case relating to business rates, the Supreme Court allowed the local authorities’ appeals and applied a Ramsay analysis outside its traditional arena of direct taxes. Liability for business rates normally falls on the person who occupies a property, but if it is empty, falls instead on the owner of the property. The companies in this case had entered into schemes to avoid rates by leasing empty properties to special purpose vehicles (SPVs) that were then either dissolved or placed into voluntary liquidation. The companies claimed not to be liable for rates because they were no longer in possession, and the SPVs avoided liability essentially through the length of time it took to complete the administrative processes that followed dissolution or liquidation. The court applied a Ramsey analysis and purposive interpretation of the legislation, concluding that liability to pay the rates remained with the (landlord) companies and had not passed to the SPVs.  See the published decision here.

EU

EU General Court delivers two State aid judgments - Amazon annulled & Engie upheld 
As reported in our last edition, the EU General Court has annulled the European Commission’s 2017 decision that advance pricing agreements approved by Luxembourg granted Amazon €250 million in state aid, holding that the Commission’s transfer pricing analysis was fundamentally flawed and that Amazon was not provided with ‘selective advantage’.  In a second decision, delivered on the same day, the Court upheld the Commission’s 2018 decision that tax rulings issued by Luxembourg to the French fuel supplier Engie conferred a selective tax advantage to the group, in breach of EU law.  We now have further analysis available from our PwC EU Direct Tax Group:

• EUDTG newsalert Amazon
• EUDTG newsalert Engie

Future-proof taxation – Commission proposes new, ambitious business tax agenda
The European Commission has adopted a Communication on Business Taxation for the 21st century to promote a robust, efficient and fair business tax system in the European Union. It sets out both a long-term and short-term vision to support Europe's recovery from the COVID-19 pandemic and to ensure adequate public revenues over the coming years. It aims to create an equitable and stable business environment, which can boost sustainable and job-rich growth in the EU and increase our open strategic autonomy. The Communication takes account of the progress made in the G20/OECD discussions on global tax reform. 

• Read our Global Tax Policy Bulletin and EU Direct Tax Group Newsalert
• See this European Commission press release and Q&A 
• Remarks by Commissioner Gentiloni at the press conference on the Communication on Business Taxation 21

European Parliament greenlights EUR 270 million programme to help tax authorities fight tax dodging
MEPs have approved the regulation establishing the Fiscalis programme, running from 2021-2027, which will provide financial resources to national tax authorities to cooperate better. MEPs succeeded in improving various aspects of the programme compared to the proposals of the Commission and member states. Read more in this European Parliament press release.

IMF report - ‘Taxing Multinationals in Europe’
The International Monetary Fund recently published a paper ‘Taxing Multinationals in Europe’ which aims to contribute to the European policy debate on corporate income tax reform.

CFE Tax Advisers Europe
CFE Tax Top 5 – Round-up of EU Tax Policy News
The latest edition looks at the following: 1) EU sets out new corporate tax reform proposals; 2) The EU Tax Observatory launches at 1 June; 3) US Senate reservations on Biden’s tax proposals; 4) EU Parliament members discuss Intra-EU harmful tax competition; and 5) Tax Transparency in Africa Report 2021. View previous editions here.

OECD

US opens with 15 percent minimum tax rate in OECD reform talks 
In a recent US Treasury press release, the US Treasury Office of Tax Policy announced the opening of discussions on a global minimum tax rate with the Steering Group of the Inclusive Framework on base erosion and profit shifting as part of OECD/G20 international tax negotiations. The US has proposed a 15% rate as a starting point for OECD-led negotiations on a global minimum corporate tax regime as part of a sweeping plan to modernize the international tax system. 

Conference of the Parties to the MLI approve new opinion
In early May, the Conference of the Parties to the MLI (the BEPS multilateral instrument) approved an opinion that sets out a series of guiding principles for addressing questions about the interpretation and implementation of the MLI. Read more in this OECD item.

OECD releases further tax dispute resolution peer review reports
Under BEPS Action 14, jurisdictions have committed to implement a minimum standard to improve the resolution of tax-related disputes between jurisdictions. The OECD has recently released the stage 2 peer review monitoring reports for Estonia, Greece, Hungary, Iceland, Romania, the Slovak Republic, Slovenia and Turkey. Read more in this OECD item.

Tax Co-operation for Development
This OECD report shows how the OECD is working with developing countries to maximise revenue collection and develop targeted and effective tax policy measures, particularly as they adjust to the challenges of the COVID-19 pandemic.

OECD welcomes Costa Rica as its 38th Member
Costa Rica has officially joined the OECD, becoming the Organisation’s 38th member in its 60-year history – and the fourth from the Latin America and Caribbean region after Mexico, Chile and Colombia. Costa Rica has now completed its domestic procedures for ratification of the OECD Convention and deposited its instrument of accession. This brings to a successful conclusion an accession process that began in April 2015. Read more in this OECD item.

Other territories

International

International Tax News - April 2021
Among the topics featured in this month's edition are: 1) Canada’s 2021 budget addresses mandatory disclosure, DST, interest limitation, and hybrid mismatches; 2) Australian Tax Office proposes hybrid rules guidance; 3) France updates list of non-cooperative states and territories; and 4) New CIT preferential policies for small and thin-profit enterprises (STEs) and super R&D deduction

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: 

• Global Digital Tax Online
  In a time when information is key and compliance is vital, GlobalDigitalTaxOnline (GDTO) is an essential tool to help navigate the complex world of tax and the reporting of various digital/electronic services. Read more about our new online subscription service.
• Digital tax byte
  The latest edition from 26 May covers: 1) the IMF guidance relating to the main challenges and tasks relating to the administration of VAT on imported digital services and low-value imported goods; 2) the US proposes that the global minimum tax rate should be at least 15%; 3) the EC sets out its long term vision and short term legislative agenda and comments on the OECD’s Pillars 1 and 2.

Australia
Australia - Draft ATO guidance on cross-border intangible arrangements
The Australian Taxation Office has released a draft Practical Compliance Guideline on cross-border arrangements connected with intangibles. The draft PCG covers a broad range of issues including intangible transfers, the development, enhancement, maintenance, protection and exploitation (DEMPE) functions, and the characterisation of intangible payments.  Read more in this PwC Tax Alert.

COVID-19 and permanent establishments 
The Australian Taxation Office has updated its guidance on the rules regarding the creation of a permanent establishment in Australia, in response to the COVID-19 pandemic. Foreign companies may be concerned about potential effects on their business and tax affairs because of the presence of employees in Australia.

Temporary loss carry-back rules - What you need to know
The temporary loss carry-back rules which were announced on 6 October 2020 are planned to be extended for an additional year - four years in total. These rules are designed to provide temporary cashflow support to companies that were previously in a tax paying position but who now find themselves in a tax loss position due to the COVID-19 pandemic and/or through obtaining faster deductions for depreciation under the new instant asset write-off measures.Read more in this PwC Tax Alert.

Temporary full expensing of depreciating assets 
As part of the response to the widespread economic impact of COVID-19, the Federal Government announced in the 2020-21 Budget that it will allow a deduction for the full cost of certain depreciating assets acquired and used by eligible businesses - a measure known as ‘temporary full expensing’. In the 2021-22 Budget, the Government announced it would extend this for an additional year to 30 June 2023. Read more in this PwC Tax Alert.

Australia highlights Common Reporting Standard obligations
The Australian Taxation Office has released a statement highlighting that the Common Reporting Standard (CRS) requires a reporting financial institution (RFI) to obtain self-certifications for all new accounts. Penalties may be imposed on RFIs that do not have strong measures in place where a valid and reasonable self-certification is not obtained.

2021-22 Victorian State Budget
The 2021-22 Victorian State Budget was delivered on 20 May 2021 by Treasurer Tim Pallas. The key feature was the recovery from the economic impact of COVID-19. However, the resulting cost is manifested in another key feature of the Budget, tax increases and new taxes and levies. Read more in this PwC Tax Alert.

Belgium
See here for latest updates.

Tax Bites Podcast – EU Business Taxation Roadmap
As reported above, on 18 May 2021, an important development in EU Tax policy took place when the European Commission announced their roadmap for Business Taxation for the 21st Century. In this podcast, PwC specialists including Isabel Verlinden (PwC’s Corporate Tax Strategy leader) discuss the development.

Costa Rica
OECD welcomes Costa Rica as its 38th Member
As reported above, Costa Rica has officially joined the OECD, becoming the Organisation’s 38th member in its 60-year history – and the fourth from the Latin America and Caribbean region after Mexico, Chile and Colombia. Read more in this OECD item.

Germany
Germany enacts law to counter real estate transfer tax (RETT) abuse
We highlighted in our last edition that the Bundestag and Bundesrat had approved legislation reforming Real Estate Transfer Tax, see our PwC Real Estate news alert. The amended law was published in the Federal Gazette on 17 May 2021, so will now come into force on 1 July 2021 as anticipated.  The amendments strengthen the rules to prevent abuse, including reducing the percentage change in ownership that triggers a transfer tax liability to 90 percent, improving oversight of purchases, and increasing the minimum holding periods for exemption.

No taxation of bogus income from a Ponzi scheme in the case of tax withheld by fraudster 
In a recent ruling, the Supreme Tax Court held that the deemed settlement of final withholding tax under Income Tax Act (ITA) also applies if the tax has been withheld by the debtor (payer) of the investment income, but not declared and paid over to the tax office. As a result, investment income from a fraudulent pyramid scheme is in principle no longer to be included in the income tax base. Read more in this PwC Germany tax blog.

Gibraltar
UK and Spain meet for first time on Gibraltar tax matters
The UK and Spain recently held their first meeting under a new mechanism intended to foster cooperation between authorities in Spain and Gibraltar. The International Agreement on Taxation and the Protection of Financial Interests between the UK and Spain regarding Gibraltar entered into force on 4 March 2021. The treaty is intended to improve tax cooperation and exchange of information between the tax authorities of Spain and Gibraltar and sets out rules and mechanisms for resolving conflicts over tax residency. Read more in this Government press release.

Greece
New tax provisions
A new bill (Law 4799/2021) has been published in the Government Gazette. The new law introduces certain amendments on tax legislation; among others, reductions on CIT and Tax Advance Payment rates, as well as exemptions from Special Solidarity Contribution. Read more in this PwC Tax Flash.

Ireland
Irish Revenue Transfer Pricing Tax and Duty Manual - what does it mean for Irish taxpayers?
The Irish Revenue recently released Part 35A-01-01, Transfer Pricing Tax and Duty Manual (Tax and Duty Manual), which seeks to give taxpayers additional guidance on the new rules introduced by Finance Bill 2019. It also issued Part 35A-01-02 on the Transfer Pricing Documentation Obligations and Part 35A-01-03 about Guidelines on Low Value Intra-Group Services, which are applicable for accounting periods prior to 1 January 2020. Read more in this PwC Suite item.

Irish SME issues pre-Budget submission 2022
The Irish SME (ISME) Association has issued a Pre-Budget 2022 submission to the Irish Government calling for a package of tax reforms to be introduced at the Budget, including changes to VAT and income taxation. See this ISME news item.

Italy
Tax settlement procedure: Italian Revenue Agency is bound by the minutes signed within a settlement agreement in compliance with the principle of protection of legitimate expectations
The Italian Supreme Court has issued a ruling concerning the binding effects of the minutes signed within a settlement agreement, highlighting some general criticalities and stating some fundamental principles with respect to the protection of legitimate expectations and to cooperation in good faith between taxpayers and the Italian Revenue Agency. Read more in this PwC Italy tax blog.

Korea
Korean Tax Update - May 2021
This issue includes: 1) Customs audit to be temporarily suspended for companies affected by the COVID-19 pandemic; 2) Government’s measures to facilitate the sale of shares provided for tax payment in-kind; 3) NTS opens a renewed statistics portal to frequently provide the latest statistical information; 4) NTS audit targets tax frauds or unfair wealth transfers; and 5) Rulings update.

Mexico
Outsourcing tax law changes
Legislation amending various tax laws to restrict the ability of companies to outsource services to related or third-party service providers, discussed in our last edition, has now been enacted.  Outsourced services are now generally prohibited, with payments for outsourcing neither deductible for tax purposes nor creditable for VAT purposes, and failure to comply with the limitations could result in significant penalties or charges of tax fraud.  These changes will significantly impact multinationals with operations or investments in Mexico.  For more detail:

• US webcast: Mexico's outsourcing services reform significantly impacts multinationals
  View a recording of our webcast, held on 27 May, by registering here.   
• Acción Inmediata: Mexico adopts labor subcontracting rules
  Listen to this episode of our Cross-border Tax Talks series from 12 May, with Doug McHoney (PwC's US International Tax Services (ITS) Leader) and David Cueller (PwC Mexico’s Tax and Legal Services Leader).

Philippines
Philippines issues FAQs on corporate tax reform law 
The Philippines Bureau of Internal Revenue has released new guidance on the tax provisions in the country's Corporate Recovery and Tax Incentives for Enterprises Act (CREATE). The guidance, in questions and answers format, is included in Revenue Memorandum Circular no. 62, dated 30 April 2021 and released on 17 May 2021. 

Poland
Plans to postpone introducing new pay and refund of WHT regime
Provisions introducing a new pay and refund withholding tax (WHT) collection mechanism in CIT, initially planned for 1 January 2019, will be postponed once again, to 31 December 2021. Further amendments to the WHT provisions will be enacted at the end of the year. Read more in this PwC Poland news item.

South Africa
Changes to SARS eFiling
The South African Revenue Service (SARS) has recently made changes to its eFiling platform. The changes will have a significant impact on how tax practitioners and taxpayers interact with SARS on the platform relating to how tax types are transferred. Read more in this PwC Tax Alert.

Spain
UK and Spain meet for first time on Gibraltar tax matters
The UK and Spain recently held their first meeting under a new mechanism intended to foster cooperation between authorities in Spain and Gibraltar. The International Agreement on Taxation and the Protection of Financial Interests between the UK and Spain regarding Gibraltar entered into force on 4 March 2021. The treaty is intended to improve tax cooperation and exchange of information between the tax authorities of Spain and Gibraltar and sets out rules and mechanisms for resolving conflicts over tax residency. Read more in this Government press release.

Switzerland
COVID-19 webinar series
See here for upcoming and recorded webinars. For the latest updates on current topics, see this PwC Switzerland Insights page.

Turkey
A new tax amnesty
A proposal submitted to the Turkish parliament on 21 May 2021 calls for another tax amnesty package, along with some other measures. Under the proposed, programme taxpayers can: 1) restructure their unpaid tax debts and other payables to the State; 2) settle their pending tax litigations; 3) protect their past accounts against potential tax audits by making voluntary tax base increase (years 2016 - 2020 inclusive); 4) correct their business records to reflect the reality of their situations; and 5) update the tax base of their fixed assets in return for a 2% tax on the surplus calculated from the revaluation. 

US
US opens with 15 percent minimum tax rate in OECD reform talks
In a recent US Treasury press release, the US Treasury Office of Tax Policy announced the opening of discussions on a global minimum tax rate with the Steering Group of the Inclusive Framework on base erosion and profit shifting as part of OECD/G20 international tax negotiations. The US has proposed a 15% rate as a starting point for OECD-led negotiations on a global minimum corporate tax regime as part of a sweeping plan to modernize the international tax system.

Treasury report provides details on President Biden’s tax proposals
The US Treasury has released a 114-page “Green Book” general explanation of tax proposals included in President Joe Biden’s fiscal year 2022 budget submission to Congress, also released on the same day. The Green Book provides new details on proposals to increase corporate and individual taxes to help offset the $4.1 trillion combined cost of President Biden’s previously proposed American Jobs Plan and American Families Plan. Read more in this PwC Tax Insights.

US income tax treaties at the start of the Biden Administration
At a public forum in April 2021, a Treasury official stated that the United States desires to amend existing income tax treaties with Switzerland and Israel, has opened tax treaty negotiations with Colombia, has completed tax treaty negotiations with Norway and Romania, and is engaged in ongoing tax treaty discussions with Croatia. This treaty activity contrasts with recent US tax treaty history, where, in 2019, following a lengthy hiatus in the tax treaty approval process, four US tax treaty protocols, which had been negotiated and signed years before, entered into force. Read more in this PwC Tax Insights. 

Treasury issues interim rule on state tax reductions and federal aid
The US Treasury Department has published an interim final rule on the administration of state and local fiscal recovery funds established under the American Rescue Plan Act of 2021 (ARPA). The interim rule, effective 17 May 2021, includes guidance on an ARPA provision prohibiting the states from using fund disbursements to “either directly or indirectly offset a reduction in the [state’s] net tax revenue.” Read more in this PwC Tax Insights.

Subscribe for US tax alerts
You can sign up for Tax Alerts issued by the US to be emailed to you. Subscribe using the link on this page.

Webcasts & podcasts: 

• Tax Readiness: Treasury's Green Book is back, adding detail to President Biden's tax proposals
  Register here to join our PwC panel on Thursday 3 June 2021 at 7pm to walk through Treasury's 'Green Book,' which adds details to President Biden's FY22 Budget proposals, and informs Congress. 
• Tax Readiness: Key state tax legislation and trends - What you need to know to navigate change
  This webcast on Tuesday 8 June 2021 at 7pm will focus on key state legislation impacting corporate, passthrough entity, individual, and indirect taxes. Speakers will highlight trends, what’s driving legislation, the potential impact and what companies should look out for and be thinking about to stay ahead of the changes. Register here.
• Tax Function of the Future: R&D Innovation and Cloud
  Cloud’ use is accelerating across the business... what’s the impact for Tax? Join us for this webcast on Wednesday 16 June 2021 at 7pm where we will explore why quantifying the bottom line tax impact of cloud computing while serving as a strategic partner for cloud efforts, such as R&D and ERP, are both critical tasks for Tax.
• Q2 financial reporting considerations
  Register here to join us on Wednesday, 23 June 2021 at 7pm where our panel of Tax Accounting Services (TAS) specialists will take a deep dive into relevant tax accounting matters and recent tax developments. 
• Cross-border tax talks 
  • Environmental, social & governance (ESG): Taxing matters
    In this episode from 26 May, Doug McHoney (PwC's US International Tax Services (ITS) Leader) is joined in person at the Westminster Studios by David Parrish (PwC's ESG Tax Leader) to discuss the umbrella term environmental, social, & governance.

Previous episodes in this fabulous series of podcasts can be found here, as well as on Spotify, YouTube and other streaming services.

• Talking tax with Industrial Products: Insights on the Biden Administration’s tax policy agenda
  In this podcast from 18 May, Scott McCandless and Janice Mays, senior members of PwC’s Tax Policy Services team, join John Livingstone, PwC’s Global Industrial Products Tax Leader, to discuss the potential implications of the Biden Administration’s tax policy agenda to industrial manufacturers.

Replays: 
A number of previous webcasts are available for replay in our US tax reform hub here, including:

• Tax Readiness: Preparing for Deals in a Changing Environment
  In this webcast held on Wednesday 26 May 2021, PwC professionals from our Tax and Deals practices had a timely discussion of the many factors impacting the current deals environment including the prevalence of ESG, the use of SPACs, and anticipated tax changes. 
• Mexico's outsourcing services reform significantly impacts multinationals
  As reported above, you can watch the replay here from this webcast on Thursday 27 May 2021, where we discussed the legislation recently published in Mexico that will significantly impact multinational entities with operations or investments in Mexico. 
• Zeroing in on your trade and supply chain strategy: How ready is your business?
  If you missed this webcast, you can watch the replay from Wednesday, 12 May 2021 where we examined potential steps that businesses can take in the near-term to proactively prepare for any changes in trade policy. 
• Tax Readiness: The intersection of ESG and Tax
  Register here to watch this webcast from Wednesday 5 May 2021 to learn more about environmental, social and governance (ESG) and how tax leaders can engage with the C-suite to align tax with ESG transformation.
• Tax Function of the Future: Keeping pace with the new operating tempo
  Watch this replay from 20 April 2021 to explore how high priority policy changes and other disruption are shaping the C-suite agenda and impacting Tax functions. Together, we will walk through tangible examples of how companies can operationalize to meet new Tax function challenges now and beyond.
• Tax Readiness: Are digital taxes here to stay?
  You can register here to watch the replay from 28 April 2021, in which we discussed the rapidly evolving environment, and how Digital Services Taxes (DSTs) are expanding beyond Europe, not just in geography, but also in scope.