Cross-border Tax Talks Pillar Two Admin Guidance Glimpses of clarity
Jul 17, 2024
Doug McHoney and Phil Ramstetter discuss OECD's Admin Guidance on Pillar 2, focusing on DTL recapture rule, cross-border tax allocation, GloBE rules, entity classification, and more. They highlight challenges in simplifying tax rules, global accounting, and enacting OECD guidance into national laws.
Chapters
Transcript
Episode notes
1 2 3 4 5 6
Intro
00:00 • 2min
OECD Administrative Guidance on Pillar 2 Rules
02:10 • 3min
Detailed Guidance on Five-Year Deferred Tax Loss Recapture Rule under Pillar 2
05:21 • 6min
Challenges in Simplifying Tax Rules and Global Accounting
11:37 • 16min
Complex Rules on Entity Classification and Allocation of Taxes in Cross-Border Structures
27:09 • 9min
Challenges in Enacting OECD Guidance into National Laws
36:33 • 2min