Special Episode: The Two-Pillar Tax Overhaul

Last week, over 130 countries announced an agreement to overhaul international tax rules. The changes may seem high-level, but should investors pay closer attention?

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Michael Zezas Welcome to Thoughts on the Market. I'm Michael Zezas, Head of Public Policy Research and Municipal Strategy for Morgan Stanley.

Todd Castagno And I'm Todd Castagno, Head of Global Valuation, Accounting and Tax within Morgan Stanley Research.

Michael Zezas And on this edition of the podcast, we'll be talking about recent developments around a major overhaul of international tax rules and what it means for investors. It's Thursday, October 14th at 10 a.m. in New York.

Michael Zezas So, Todd, I really wanted to talk with you after last week's announcement by more than 130 countries about an agreement to undertake a major overhaul of international tax rules. Central to the agreement appears to be a change in how companies are taxed and a new 15% global minimum tax rate. So, investors might see a headline like this and think it's one of those things that sounds important, but maybe a bit too high level to matter. But you think investors should pay attention to this.

Todd Castagno Right, it's big news. There are really two key motives driving what is referred to as a two-pillar global tax agreement, and this motivation provides really important context. So let's start with pillar one. There's a growing desire from certain countries to change who gets to tax the largest and most profitable corporates. So Michael, in a modern marketplace, companies can engage and transact with consumers in countries where they may not have much or any physical presence. So the first pillar of this agreement proposes to reallocate profits of the largest and most profitable companies to where they transact with customers. Then there is desire to stop what's often referred to as the 'race to zero' in terms of corporate tax rates. So under pillar two of the agreement, countries will need to adopt a 15% minimum tax rate structure on corporate foreign income. So why should investors care? A few reasons: Not to overstate the obvious, but tax rates are likely going up for multinationals if this is implemented. There are also important geopolitical dynamics. These changes have the potential to significantly change where corporates invest. And countries have been increasingly imposing unilateral taxes, particularly on digital services. Those taxes are complicating trade relationships. Pillar one seeks to remove those taxes so trade dynamics may actually improve.

Michael Zezas OK, so assuming these guidelines are implemented globally, what's your expectation about which industries overall could see the most headwinds?

Todd Castagno Well, it's an interesting question. Not all sectors and industries will be impacted equally. According to our analysis, technology hardware, media services, pharmaceuticals and broader health care appear most exposed to both pillars.

Michael Zezas OK, so the concept is that some industries' tax burdens are going to be affected more than others. Can you walk us through a specific example?

Todd Castagno Yes. Technology hardware appears predominately exposed to both pillars. Why is that? Manufacturing and IP are centrally located, and the industry currently benefits significantly from tax incentives, which often drive a very low tax rate. This illustrates a potential political tension, as countries are currently motivated to provide more tax and R&D incentives given the current supply constraints. So, it'll be interesting to see how countries attempt to incentivize under a new minimum tax rate system.

Michael Zezas OK, so last question here. Just because countries have agreed to pursue these tax changes doesn't mean these changes are imminent. They obviously require countries to go back and change their own laws. And regular listeners may know that our base case is that the US could soon raise corporate taxes, including a potential hike in the global minimum tax rate to 15%. So, how much do the current tax changes proposed in the U.S. already reflect this international tax agreement?

Todd Castagno So what's notable is pillar two really emerged as a function of the tax bill passed under the prior U.S. administration. Today, the U.S. is the only country with a minimum tax remotely similar to what's being proposed under pillar two. However, there are both rate and structural differences. Our base case is 15% in line with the agreement. But Michael, as you know, Congress and administration have proposed higher rates. What's also important is the structure. So, today's U.S. system applies a minimum rate on aggregate foreign income. What's notable about Pillar two is it would apply that rate on a country-by-country basis. So, what that means is many companies may be exposed to a new minimum tax rate structure versus what's in the U.S. today.

Todd Castagno But before we close, Michael, taking all this into account, what could this mean for markets moving forward? Do we think these changes are already in the price?

Michael Zezas You know, it's an important question that really defies having a simple answer. In the view of our Equity Strategy Team, the impact of these tax changes to U.S. companies bottom lines probably isn't fully appreciated yet and could cause some short-term market weakness. But beyond that, these tax changes are part of a broader fiscal package that spends more than it taxes. And so that should continue to support robust economic growth into 2022. So that makes the medium-term outlook rosier for risk assets.

Michael Zezas Todd, thanks for taking the time to talk today.

Todd Castagno Great talking with you, Michael.

Michael Zezas As a reminder, if you enjoy Thoughts on the Market, please take a moment to rate and review us on the Apple Podcasts app. It helps more people find the show.