Two weeks to 4 March 2022
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
UK
Finance Act 2022 receives Royal Assent
The Finance (No.2) Bill has received Royal Assent.
Treasury Committee investigates UK’s tax burden
The Treasury Committee examined the level of the current tax burden in the UK and whether the Chancellor’s intention to cut taxes before the next election is sustainable in a session on 28 February at which Jon Richardson was one of the witnesses. You can read the transcript and watch the meeting here.
Super-deduction - timing is everything
Rishi Sunak announced the “super-deduction” at the Spring Budget last year with the aim to encourage investment in improving productivity, a long-term ambition for the UK. That was eleven months ago and, whilst the super-deduction is still a very positive step and most companies are keen to benefit from the regime where possible, a number of quirks in the legislation are starting to arise meaning that actually making a claim can be more difficult than originally envisaged. Read more in this PwC blog.
HMRC Note - Purchase of own shares – multiple completion contracts
HMRC have provided the CIOT with a note which clarifies their position on the purchase of own shares legislation at s1033 Corporation Tax Act (CTA) 2010 where the transaction is effected through a multiple completion contract and whether the seller remains connected with the company immediately after the purchase, in particular their view that the word ‘possesses’ in s1062(2) CTA 2010 refers to legal, as opposed to beneficial, ownership. You can read the note here.
UK proposes beneficial owner register for properties
In response to Russia’s invasion of Ukraine, the UK government has introduced a bill that would require anonymous foreign owners of UK property to reveal their real identities to ensure criminals cannot hide behind secretive chains of shell companies. Read more in this press release.
Consultations
- Online Sales Tax: Policy Consultation
HM Treasury has launched a consultation to explore the proposal for an online sales tax (OST) as a means to rebalance the taxation of the retail sector between online and in-store retail. The consultation closes on 20 May 2022. - Uncertain Tax Treatment guidance
HMRC has published final guidance following the outcome to the consultation on uncertain tax treatment.
UK and New Zealand sign comprehensive trade deal
The International Trade Secretary signed the UK-New Zealand free trade deal with New Zealand Minister Damien O’Connor in London on 28 February 2022 in London. Read this press release.
EU
Council reviews list of non-cooperative countries for tax purposes
In its regular biannual review, released 22 February, the European Council has decided to make no change to its blacklist of non-cooperative tax jurisdictions. The following countries therefore remain on the list: American Samoa, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, US Virgin Islands and Vanuatu. Several territories were added to Annex II, known as its grey list: Anguilla, Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, Israel, Montserrat, Thailand, Tunisia, Turks and Caicos Islands and Vietnam. Read more in this press release.
Webcast 15 March: Are you ready for the digital platform reporting rules under DAC 7?
By the end of 2022, all EU Member States must implement new rules regarding the Directive on administrative cooperation in the field of taxation. It includes the obligation for digital platforms to report on their sellers and a legal framework to conduct joint audits (DAC7). Find out more and register here for a webcast on Tuesday 15 March at 10am UK time where PwC will focus on the part of DAC 7 that introduces a reporting obligation for digital platforms located both inside and outside the EU (and the automatic exchange of information with respect to this information).
CFE Tax Advisers Europe
- EU Tax Policy News Top 5
The latest round-up of EU Tax Policy news from the Confédération Fiscale Européenne (CFE). This edition looks at the following: 1) EU Council reviews tax blacklist; 2) OECD publishes public comments on Draft Pillar I Nexus & Revenue Sourcing Rules; 3) Applications Open: CFE Tax Advisers Europe’s 2021 Albert J. Raedler Medal Award; 4) OECD consultation on draft rules for Tax Base Determination under Pillar I; and 5) Investment Tax Incentives Database. Visit their latest news page here. - Global Tax Top 10 February 2022
The February 2022 issue looks at the following: 1)OECD update on Pillar 1 & 2 developments; 2)EU Council reviews tax blacklist; 3)OECD to establish new Inclusive Framework on carbon pricing; 4) Applications open: CFE Tax Advisers Europe’s 2021 Albert J. Raedler Medal Award; 5) OECD public consultation on draft Pillar I nexus & revenue sourcing rules; 6) EU to extend VAT reverse charge mechanism; 7) Global Forum publishes 2022 Capacity Building Report; 8) European Parliament adopts Resolution on reducing EU VAT Gap; 9) OECD consultation on draft rules for tax base determination under Pillar I; and 10) Investment Tax Incentives Database.
OECD
Pillar Two Model Rules - further insights
- OECD Tax Talks webinar - Monday 21 February
With a number of recent and upcoming developments in the OECD’s international tax agenda, this live webinar with experts from the OECD Centre for Tax Policy and Administration provided the latest update on the current work, in particular on the implementation of the agreement reached last October to reform international tax rules and on upcoming public consultations. Watch the replay here. - Transfer pricing podcast: The opening – Transfer pricing is a critical piece of the Pillar Two chessboard
In this TP Talks episode, Horacio Peña (PwC’s Global Transfer Pricing Leader), Kartikeya Singh (Transfer Pricing Principal in PwC’s US National Tax practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD Pillar Two Model Rules, including an overview of the rules, some of the nuances and elements of complexity, and highlights the role of transfer pricing in the new system of Pillar Two taxation.
Pillar One draft Model Rules
- OECD launches Public Consultation on Pillar One draft Model Rules on Tax Base Determinations
As reported previously, on 18 February 2022, the OECD released draft Model Rules with respect to the Tax Base Determinations under Amount A of Pillar One, for comment by 4 March. This is the second in a series of up to thirteen sets of rules that the OECD is expected to release over the coming months, with very short comment periods, as part of a 'rolling consultation'. Our Tax Policy Alert provides a short overview of the draft Model Rules and some initial observations. - Policy on Demand series: Ramifications -- and next steps -- of Pillar 1 draft model rules
In this episode, Will Morris discusses the two sets of Pillar 1 draft rules recently released by the OECD. He also shares his insights on next steps and timing. - Public comments received on the draft rules for nexus and revenue sourcing under Pillar One Amount A
On 4 February 2022, the OECD invited public comments on the Draft Rules for Nexus and Revenue Sourcing under Pillar One Amount A to assist members in further refining and finalising the relevant rules. The OECD has now published the public comments received.
MLI
- Future of Vietnam double tax treaties post-MLI
Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“the Convention” or “the MLI”) on 9 February. As a result, 75 of Vietnam’s double tax treaties could potentially be altered once the MLI comes into effect. Taxpayers should be aware of these potential changes to these tax treaties and the impact this may have on their plans for structuring their investments and transactions to claim treaty benefits in Vietnam. Read more in this PwC NewsBrief. - Bahrain and Romania deposit instruments for the ratification of the Multilateral BEPS Convention
Bahrain and Romania have deposited their instruments of approval or ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI), which now covers over 1800 bilateral tax treaties. For Bahrain and Romania, the Convention will enter into force on 1 June 2022. The text of the Multilateral Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available here.
OECD condemns Russian aggression
The OECD has strongly condemned Russian aggression and effectively shut Russia out from engagement with the body. In a statement issued on 25 February 2022, the OECD said: "Following on from yesterday's statement condemning the large-scale aggression by Russia against Ukraine in the strongest possible terms and as part of its urgent reconsideration of all cooperation with Russia, the OECD Council has taken a number of initial decisions today."
OECD releases third batch of transfer pricing country profiles
The OECD has released the third batch of 2021/2022 updates to the transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of 28 jurisdictions. The updated country profiles add new information on countries’ legislations and practices regarding the transfer pricing aspects of financial transactions and the application of the Authorised OECD Approach (AOA) on the attribution of profits to permanent establishments. In addition, the country profiles reflect updated information on a number of transfer pricing aspects such as methods, comparability, intra-group services, cost contribution agreements, transfer pricing documentation and administrative approaches to prevent and resolve disputes.
OECD builds an Investment Tax Incentives database
The OECD has constructed an Investment Tax Incentives database which compiles granular details on corporate income tax (CIT) incentives for investment. This paper presents the methodology used to develop the database and insights from an initial data collection in 36 developing countries.
Chile joins the OECD International Compliance Assurance Programme
ICAP is a voluntary risk assessment and assurance programme to facilitate open and co-operative multilateral engagements between MNE groups and tax administration in jurisdictions where they have activities. See here for a full list of the tax administrations participating in ICAP and further information on the programme.
Jamaica's Marlene Nembhard-Parker appointed Co-chair of OECD/G20 Inclusive Framework on BEPS
The OECD/G20 Inclusive Framework on BEPS has elected Marlene Nembhard-Parker of Tax Administration Jamaica (TAJ), Ministry of Finance and the Public Service as its new co-chair. Ms. Nembhard-Parker will lead the group with Ms. Fabrizia Lapecorella of Italy who, as Chair of the OECD’s Committee on Fiscal Affairs (CFA), currently serves as Chair of the Inclusive Framework on BEPS. Read more in this OECD announcement.
Global Forum and Global Relations and Development division release course on the automatic exchange of financial account information
The Global Forum Secretariat and the OECD Centre for Tax Policy and Administration’s Global Relations and Development division has released a new e-learning course, to help tax officials better understand the Standard for Automatic Exchange of Financial Account Information in Tax Matters (CRS-AEOI). The course is available in English (French and Spanish versions to follow shortly) and is offered free of charge to all officials from tax administrations and ministries of Finance via the KSPTA platform.
Other territories
International
International Tax and Transfer Pricing Seminar
In this webinar, which took place on 3 March, our experts focussed on key updates to the international tax and transfer pricing environment and what they mean for business in 2022. It had a particular focus on OECD Pillar 2 Model Rules, including their interaction with US tax reform proposals, and also picked up on a number of other hot topics including the evolving transfer pricing thinking on rewarding IP and the importance of people functions.
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’s Pillars 1 & 2
See our OECD section above. - Webcast 15 March: Are you ready for the digital platform reporting rules under DAC 7?
PwC is organising a webinar focusing on the part of DAC 7 that introduces a reporting obligation for digital platforms located both inside and outside the EU (and the automatic exchange of information with respect to this information). Find out more and register here. - Digital tax byte
The latest edition from 28 February includes details of Pillar One consultations on Nexus/ Revenue Sourcing and on Tax Base plus the expectation of 11 similar papers and an imminent OECD Pillar Two consultation. We also note a push by the EU Council's French Presidency to see Pillar Two impacts in the EU. The US Trade Representative has meanwhile sent Canada comments on its pending DST. Singapore's Budget announced consideration of a domestic minimum top-up tax. The Danish government's proposed introduction of a streaming levy is also under the spotlight and we comment on the Dominican Republic's consultation on VAT on digital services provided by foreign suppliers. The UK is meanwhile consulting again on the possibility of an online sales tax. Malaysia is providing an amnesty covering late registration/payment of its tax on digital services.
Environmental, Social and Governance (ESG)
- Tax: A cornerstone of the ESG equation
ESG (environmental, social and governance) is an umbrella term used to express a company's collective commitment to environmental and social factors. To date, tax has largely been absent from the ESG conversation, yet it is a component that spans each of the three pillars. Not only is tax becoming an indicator of a company's societal commitments, it is also being used as a mechanism to facilitate the transition to a net zero world. In the first of our series of insights on the interaction between tax and ESG, we explore some of the key tax touchpoints across the ESG landscape. - Taxing Crypto and Digital Assets - Emerging Global Tax Policy and Latest Trends
In this recent webcast, our PwC subject matter experts discussed the findings with an OECD panellist and shared insights into the latest global tax policy initiatives for the newly emerging trends, and what they mean for multinational enterprises, tax authorities and other stakeholders. Register here to watch the replay.
Australia
CCIV legislation passed - which train will lead us to the right destination?
The passing of the Corporate Collective Investment Vehicle (CCIV) legislation represents a milestone development that began 13 years ago with the recommendations of the ‘Johnson Report’ in 2009. The priority has been to develop the CCIV into a ‘minimum viable product’ (MVP) rather than seek to perfect it. Practical market needs will determine both the necessity and priority of refinements. Implementation is being undertaken by the Australian Taxation Office (ATO) and a working group has already been created. Read more in this PwC Tax Alert.
Monthly Tax Update - March 2022
Read the latest edition of PwC Australia’s monthly tax update - keeping you up to date on the latest Australian and international tax developments.
Austria
Austria enacts Law for Budget 2022 tax changes including Eco-social Tax Reform Act 2022
The Austrian Government has published in its Official Gazette legislation to implement measures announced in the territory's 2022 Budget. One of the measures, the so-called "Eco-social tax reform" includes a two percentage point cut to the corporate tax rate, from 25 percent to 24 percent in 2023, and to 23 percent in 2024. See this PwC Tax News item for the changes made since the consultation draft and the bill.
Belgium
See here for latest updates.
Client webcast 15 March: Are you ready for the digital platform reporting rules under DAC 7?
As noted above, PwC Belgium is organising a webinar focusing on the part of DAC 7 that introduces a reporting obligation for digital platforms located both inside and outside the EU (and the automatic exchange of information with respect to this information).
Canada
2022 British Columbia budget – Tax highlights
On 22 February 2022, British Columbia’s Minister of Finance presented the province’s budget. The budget does not change corporate or personal income tax rates, but does: 1) introduce the clean buildings tax credit, for eligible building retrofit expenditures that improve energy efficiency; 2) temporarily expand the budget for the small business venture capital tax credit, for clean technology investments; 3) extend several business and personal tax credits, including the scientific research and experimental development (SR&ED) and training tax credits; and 4) require marketplace facilitators, effective 1 July 2022, to collect and remit provincial sales tax (PST) on certain sales and leases made in British Columbia. This Tax Insights discusses these and other tax initiatives outlined in the budget.
Ontario’s new business registry for filing annual returns and beneficial ownership register coming to Ontario
Businesses operating in Ontario should ensure that they are aware of, and comply with, the following: 1) effective 19 October 2021, Ontario corporations and non-Canadian extra-provincial corporations must register and file their annual returns using the Ontario Business Registry; 2) beginning 1 January 2023, privately held Ontario corporations will be required to create and maintain a register of individuals who hold significant control; and 3) retroactive to 25 October 2021, non-competition provisions in Ontario employment agreements are prohibited and void (exceptions apply). Read more in this PwC Tax Insights.
China
PwC assisted companies to sign the first batch of unilateral APAs under the simplified procedures in China
PwC has assisted two companies, located in Jiangsu Province and Guangdong Province respectively, to successfully sign unilateral APAs under the simplified procedures. These are the first two signed unilateral APAs cases under the simplified procedures across China since the Public Notice on Matters Regarding the Application of Simplified Procedures of Unilateral Advance Pricing Arrangements ("APAs") (STA Public Notice [2021] No. 24 became effective. The introduction of the simplified procedures resulted in the above two cases taking only four months from application to formal signing, providing companies with tax certainty on their transfer pricing arrangement in a quick and efficient manner. Read more in this PwC News Flash.
Finland
Scope of transfer pricing adjustment provision broadened
Finland has introduced a new amendment to the Tax Assessment Procedure Act which entered into force on 1 January 2022. The new amendment widens the scope of the Finnish transfer pricing adjustment provision by enabling the Finnish tax authorities to: 1) Disregard or recharacterize intra-group transactions agreed by the parties under certain circumstances, and 2) Apply the OECD Transfer Pricing Guidelines in full in proportion to transfer pricing adjustments in Finland. Read more in this PwC Tax Insights.
Germany
Draft bill for the amendment of rules for interest on tax arrears and refunds
The Federal Ministry of Finance has published a draft bill regulating the statutory interest rate for interest on tax arrears and tax refunds. The provision is to be applied retroactively following a decision of the Federal Constitutional Court in July 2021 giving the legislature time until 31 July 2022 to create a new regulation in line with the constitution for interest periods from 2019 onwards. Read more in this PwC tax blog.
Greece
Development Law - new tax incentives introduced to encourage economic development
Law 4887/2022 “Development Law - Greece Strong Development” was approved by the Greek Parliament on 4 February 2022. It introduces a number of incentives to promote the economic development of the country and be the cornerstone in the support of all business sectors. Read more in this PwC Tax Flash.
Hong Kong
2022/23 Hong Kong Budget | Revitalising Hong Kong's economy
The Financial Secretary announced the 2022/23 Budget on 23 February. Key highlights include: 1) The two-tiered profits tax rates for companies (8.25%/16.5%) and unincorporated businesses (7.5%/15%) remain unchanged; 2) A proposed 8.25% tax concession to attract more maritime enterprises to establish a presence in Hong Kong; 3) Following the OECD’s work in the international tax area regarding base erosion and profit shifting (i.e. BEPS 2.0), continue discussions with impacted large multinational groups on Hong Kong’s implementation of BEPS 2.0 to ensure Hong Kong’s tax regime is in line with international consensus while retaining the renowned simplicity, certainty and transparency of the territorial tax regime. Visit our Budget webpage to find out our responses to this year’s Budget and recommendations for making positive and sustained impacts for the economy, businesses, and individuals.
Hong Kong announces profits tax return filing deferment
Hong Kong's Inland Revenue Department has announced an extension to the deadline for filing 2020/21 profits tax returns for businesses whose accounting date falls within 1 January 2021 to 31 March 2021, postponing the deadline to 30 April 2022.
Ireland
Irish Revenue updates guidance on CFC rules
The Irish Revenue Commissioners recently issued Revenue eBrief No. 039/22, and updated guidance on controlled foreign company (CFC) rules. Topics covered include: 1) the definition of a CFC; 2) the procedures for determining residence and CFC charges; 3) exemptions for low profit margins and for low accounting profits; 4) procedures for determining exemption periods; 5) the effective tax rate test; and 6) defensive tax measures against countries currently listed on the EU list of non-cooperative jurisdictions, effective for accounting periods beginning on or after 1 January.
Updated guide on Associated Companies Stamp Duty Relief - treatment of partnerships
The Irish Revenue has updated its Stamp Duty Manual on Associated Companies Relief in section "5. Bodies Corporate" to provide that Irish limited and general partnerships, and foreign partnerships which are similar in form and character to Irish partnerships, may be ”looked through” for the purposes of establishing the bodies corporate comprising a group for stamp duty purposes.
Italy
Cryptocurrencies – Decree on the Register of Operators
A Decree of the Ministry of Economy and Finance, concerning the procedures and timelines by which virtual currency service providers and digital wallet service providers are required to disclose their operations in Italy, was recently published in the Official Gazette. The Decree applies the anti-money laundering provisions introduced with article 17-bis of Legislative Decree no. 141 of 13 August 2010 and article 8 paragraph 1 and article 8-bis of Legislative Decree no. 90 of 25 May 2017. See this PwC tax blog.
Japan
Japan establishes new exempted structures for investment management businesses
As outlined in our previous newsletter in July 2021, the Financial Services Agency of Japan introduced new business structures to attract foreign investment management businesses, where they may enjoy exemption from registration as financial instruments business operators. The new exemption structures came into force on 22 November 2021. Read more in this News Alert, which provides an overview and describes the key requirements of these exemptions.
Malta
Tax Audits - are you next on the Revenue’s hit list?
The tax environment is becoming increasingly complex and challenging - tax authorities are constantly under pressure to carry out more tax audits and to strengthen the tax administrative / penalty systems to combat tax evasion and non-compliance. As part of this global effort, Maltese tax authorities have also been revamping the current tax administration practices to crackdown tax evasion. As also announced by the Minister of Finance in the last Budget speech, annual interest rates on outstanding income tax and VAT balances are expected to increase to 7.2 % (more than twice the current rate) with effect from 1 June 2022, with reductions on interest/ penalties expected to be more difficult. Read more in this PwC Tax Insights.
Middle East
Bahrain deposits ratification instrument for MLI
Bahrain has deposited its instrument ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI). For Bahrain, the Convention will enter into force on 1 June 2022. The text of the Multilateral Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available here.
Saudi Arabia: Approved amendments to the RETT Implementing Regulations
The Board of Directors of Zakat, Tax and Customs Authority (‘ZATCA’) has approved the amendments/additions to various Articles to the Implementing Regulations of Real Estate Transaction Tax (“RETT”) with effect from 18 February 2022. Through the amendments, ZATCA extends exclusion from RETT application in certain cases and also clarifies the due date of RETT payment in cases e.g. sale of map etc. Read more in this PwC news item.
Netherlands
Dutch Supreme Court judgment on deductibility of interest rate swaps
On 25 February 2022, the Supreme Court issued an important judgment (in Dutch) in which it addressed the tax treatment of redemption fees owed by a company or organisation upon termination of financing instruments (loans and the like). The Court held that the lump sum payment of interest rate swaps that cover a variable interest loan that is separate from the old loan may be charged against taxable profits immediately. Read more in this PwC news item.
Philippines
Attracting foreign investment in the post-pandemic future
With the gradual easing of COVID-19 restrictions and the decline in cases, there are signs of a rebound for the Philippine economy. More businesses have reopened, and several others have recalibrated their operations to align with anticipated demand in the post-pandemic future. Read this PwC article highlighting some key considerations for foreign investors seeking to start or expand their businesses in the Philippines.
Romania
Romania deposits ratification instrument for MLI
Romania has deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Convention or MLI). For Romania, the Convention will enter into force on 1 June 2022. The text of the Multilateral Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available here.
Russia
Foreign companies have two months to disclose information about their beneficiaries
This tax brief focuses on the requirement set forth in the Russian Tax Code (RTC) with respect to foreign entities that have registered with the Russian tax authorities for any reason. Such foreign entities are required to disclose their beneficiaries as at 31 December by 28 March 2022 (and thereafter on an annual basis). The disclosures should contain information about all direct shareholders, as well as about any indirect shareholders that hold at least a 5% share. For many entities that are committed to transparency in principle, this requirement could be difficult to comply with in practice.
OECD condemns Russian aggression
As noted above, the OECD has strongly condemned Russian aggression and effectively shut Russia out from engagement with the body. In a statement issued on 25 February 2022, the OECD said: "Following on from yesterday's statement condemning the large-scale aggression by Russia against Ukraine in the strongest possible terms and as part of its urgent reconsideration of all cooperation with Russia, the OECD Council has taken a number of initial decisions today."
Singapore
Singapore issues more guidance on IBOR reform
The Inland Revenue Authority of Singapore has fleshed out its guidance on the tax implications of Interbank Offered Rate (IBOR) reform. Earlier, in January 2022, IRAS released transfer pricing guidance for related-party loans. The changes bring with them considerable tax risks for companies that have previously drafted contracts referencing IBOR, as well as potential transfer pricing implications. Among other things, having to redraft a contract to adapt it to the changes may result in a tax charge, where recognition of income or gain is currently deferred; may result in a taxpayer losing access to historic tax breaks (for instance, where grandfathering arrangements are in place); and may result in a transfer pricing adjustment, notably for intra-group loans.
South Africa
South African Budget 2022
The South African Finance Minister, Enoch Godongwana, presented his Budget speech on 23 February. Read this PwC alert which discusses the main tax proposals from the 2022 Budget and visit our Budget 2002 webpage for further insights on what the 2022 Budget Speech means for you and your business.
Switzerland
For the latest updates on current topics, see this PwC Switzerland Insights page.
US
California updates P.L. 86-272 guidance due to “technological advancements”
The California Franchise Tax Board (FTB) recently issued a Technical Advice Memorandum (TAM) addressing whether the protections of P.L. 86-272 apply to certain fact patterns “common in the current economy due to technological advancements” for purposes of California income and franchise tax. The FTB’s guidance comes six months after the Multistate Tax Commission (MTC) adopted a revised statement of information on the application of P.L. 86-272, taking the position that such protections generally are lost when a business interacts with a customer via the business’s website or app. Read more in this PwC Tax Insights.
Subscribe for US tax alerts
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Webcasts, blogs & podcasts:
- Cross-border tax talks: ATAD3 - impacting the financial services industry and more
In this episode from 24 February, Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Puneet Arora, PwC ITS Partner and PwC’s Financial Services Consulting leader. They discuss the latest EU anti-tax avoidance directive (ATAD3), diving into the details and impact it could have on the financial services industry; the importance of modelling for Pillar Two; and the G in ESG, governance. - Policy on Demand series
- Ramifications -- and next steps -- of Pillar 1 draft model rules
In this episode, Will Morris discusses the two sets of Pillar 1 draft rules recently released by the OECD. He also shares his insights on next steps and timing. - Podcast: Week in Review
- Crisis, uncertainty, and hope – in this episode, Todd Metcalf shares why these words embody his takeaways from this week and what companies should focus on in the near term.
- In this episode, Janice Mays shares her thoughts on the status of legislation and looks ahead to President Biden’s State of the Union address next week. She also answers the question that she received most this week: Will Congress act quickly on Section 174?
- Tax Readiness: The future of tax - What’s your workforce and tax technology strategy in 2022?
Register here to join our panel of specialists on Wednesday 9 March at 7pm as they discuss how businesses are facing a growing list of challenges in 2022 and are increasingly relying on their people and technology systems to do more. Companies have to execute a variety of tasks in order to adhere to burdensome compliance requirements, workforce issues, and evolving tax policy, including OECD’s Pillar Two. - Banking & Capital Markets Tax Updates Webcast
Join us at 7pm on Wednesday 30 March for an in depth discussion on up-to-the-minute taxation issues and other hot topics impacting financial accounting and reporting of income taxes. Register here.
Replays:
A number of previous webcasts are available for replay in our US tax reform hub here, including:
- Tax Readiness: Capitalizing research expenditures and software development costs — issues and implications
The 2017 tax reform act amended Section 174, effective for tax years beginning after 2021, to require capitalization and amortization of research expenditures and software development costs. Watch the replay from 23 February where our panel of specialists discussed the implications of this new capitalization requirement, including potential impacts on the research credit, foreign tax credits, tested income, Section 861 allocation, Section 482 cost sharing arrangements, and state and local taxes. - Tax Readiness webcast: 2022 Tax Policy Outlook - Managing Constant Change
In this webcast, our panel of specialists dived into this year’s Tax Policy Outlook, discussing the key role that tax can play around potential changes to US and global tax policy, a world of technological disruption, fractured geopolitics, the enduring impacts of the COVID-19 pandemic, and increased focus on ESG concerns. Register here. - Tax Readiness: Impacts of the 2021 final foreign tax credit regulations
The Treasury and IRS recently released final regulations addressing various aspects of the foreign tax credit (FTC) regime. Listen to our panel of PwC specialists in this webcast held on Wednesday 19 January as they discuss these final regulations and the impact they may have on taxpayers. Register here for the replay. - Tax Readiness: The OECD's Pillar Two Model Rules on a global minimum tax
Watch the replay from this webcast held on Monday 10 January 2022, where our panel discussed the Model Rules, including definitions, scope, timeline, tax accounting issues, administration of the rules, and touch briefly on the 22 December EU draft Directive on minimum taxes, as well as the interactions with current US legislative proposals.
Other updates
For regular updates on this topic, check out our US tax reform hub on The Suite here.
Vietnam
Future of Vietnam double tax treaties post-MLI
As previously reported, Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“the Convention” or “the MLI”) on 9 February. As a result, 75 of Vietnam’s double tax treaties could potentially be altered once the MLI comes into effect. Taxpayers should be aware of these potential changes to these tax treaties and the impact this may have on their plans for structuring their investments and transactions to claim treaty benefits in Vietnam. Read more in this PwC NewsBrief.