Zoom online event : 27th and 28th January 2022
After several years of negotiations, in October 2021, the Inclusive Framework of the OECD officially agreed on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy.
Pillar Two of the solution contains three interconnected rules viz, the Income Inclusion Rule (IIR), Undertaxed Payments rule (UTPR) and the Subject to Tax Rule (STTR). The objective of these three rules is to ensure that an in scope MNE is subject to a minimum tax rate with respect to its profits. The OECD has now released the model rules and the EU Commission has released the proposed EU Directive to implement these rules.
Against this backdrop, the first part of the event will be dedicated to a discussion on the current tax policy challenges to implement the rules, especially, in Switzerland and some other selected jurisdictions.
The second part will discuss key technical issues with respect to implementing the Pillar II agreement in practice. The first session of this part will deal with issues pertaining to determining Effective Tax Rates (ETRs) for applying the IIR and the UTPR and issues such as addressing temporary differences, pre regime / in regime losses, carve outs and simplification options.
The second session will be dedicated to the interaction between Pillar Two and Transfer Pricing rules. In this regard, we will discuss issues pertaining to allocation of profits to PEs / subsidiaries to calculate ETRs, the impact of post filing transfer pricing adjustments in ETR computation and potential spillover effects of Pillar I on Pillar II.
The third session will discuss the implementation of these rules in Switzerland and a discussion on the future policy outlook towards tax competition.
The fourth session will be dedicated to the STTR and key issues associated with the rules such as computation of Adjusted Nominal Rates, simplification options and implementation challenges of this rule through a Multilateral Instrument.
The fifth session will address key compatibility issues between the Pillar II Globe rules with tax treaty and other Investment Law Obligations. The part will also discuss the dispute resolution framework associated with the inconsistent / misapplication of the Pillar II rules.
We will then move to third part of the event which will be dedicated to the implementation of the Pillar II Globe rules in the EU and US.
The event, which is organised by the Tax Policy Center of the University of Lausanne and the Institute of Tax Law of KU Leuven is intended to provide a neutral platform to debate the latest developments in the area of Pillar Two and its possible practical and policy implications. To that end, this event will consist of presentations and debates by leading representatives of international organizations, academia, and businesses.
To download the fyler and the registration form, please clik here