Cross-border Tax Talks Pillar Two around the World: Country updates
Dec 6, 2024
Stewart Brant, Managing Director at PwC’s Tax Policy Services, shares his expertise on international tax policy and the Pillar Two initiative. The conversation navigates the current global enactment of Pillar Two, revealing varied country applications and retroactive rules. They also discuss potential impacts of a Trump administration and the UN's evolving role in shaping these policies. The light-hearted baseball banter adds a unique touch to the serious discussions, making tax compliance a bit more engaging.
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DTSG's Expanding Scope
- The Digital Tax Study Group (DTSG) tracks Pillar 1 and Pillar 2 developments, originally focusing on tech.
- Now, it includes various sectors due to Pillar 2's broad impact on multinationals.
Pillar 2 in the EU
- Most EU members have adopted Pillar 2 rules, with some facing infringement actions for delays.
- Some smaller EU states have deferred IIR/UTPR implementation until 2030.
Retroactivity Challenges in Poland
- Poland faces challenges enacting Pillar 2 retroactively due to constitutional limitations.
- This issue also affects countries applying OECD administrative guidance retroactively.