
Cross-border Tax Talks
UK Pillar Two: Painting while the paint dries
Dec 12, 2023
Matt Ryan, London-based international tax partner and PwC UK’s Pillar Two Leader, joins Doug McHoney to discuss the challenge UK legislators face in enacting legislation while the OECD guidance is still changing. They explore practical next steps for UK-parented taxpayers, complexities created by UK rules around safe harbors, and issues with partnerships and deferred taxes.
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Quick takeaways
- Enacting UK Pillar Two legislation amidst changing OECD guidance poses challenges and requires addressing key differences.
- UK taxpayers need to prepare for the complexities of safe harbors, partnerships, deferred taxes and seek further guidance.
Deep dives
Overview of UK Pillar 2 Engine
The podcast episode delves into the UK Pillar 2 engine developed by PWC, which revolutionizes Pillar 2 modeling, provision, and compliance calculations. The engine, created by a team of Pillar 2 tax experts, utilizes over 20 years of international tax technology and provides a centralized rules engine. While the engine is currently available as a service, it will be licensable in July 2024. The podcast highlights the benefits of the UK Pillar 2 engine in terms of improved efficiency and accuracy in navigating the complex landscape of international taxation.
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