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.

38:32

Episode guests

Phil Ramstetter

Doug McHoney

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Episode notes

Podcast summary created with Snipd AI

Quick takeaways

The OECD released detailed administrative guidance on Pillar 2, focusing on rule operation and assisting jurisdictions in implementing the rules.

The guidance clarifies the treatment of deferred tax liabilities in Pillar 2, emphasizing compliance burdens and impact on covered taxes.

Deep dives

PwC's Pillar 2 Engine: A Game Changer

PwC introduces the Pillar 2 engine, revolutionizing modeling, provision, and compliance calculations. Utilizing over 20 years of tax technology, this rules engine, developed by global experts, is available for service and license across the globe.

Intro

2min

OECD Administrative Guidance on Pillar 2 Rules

3min

Detailed Guidance on Five-Year Deferred Tax Loss Recapture Rule under Pillar 2

6min

Challenges in Simplifying Tax Rules and Global Accounting

16min

Complex Rules on Entity Classification and Allocation of Taxes in Cross-Border Structures

9min

Challenges in Enacting OECD Guidance into National Laws

2min

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, International Tax Partner and former Tax Policy Consultant at Business at OECD (BIAC). Doug and Phil discuss the OECD’s Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the allocation of cross-border taxes, deferred tax accounting, transactions within the GloBE rules, entity classification and treatment, and the expectation of more OECD administrative guidance in the second half of 2024.

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Cross-border Tax Talks

Pillar Two Admin Guidance Glimpses of clarity

Episode guests

Podcast summary created with Snipd AI

Quick takeaways

Deep dives

PwC's Pillar 2 Engine: A Game Changer

OECD's Administrative Guidance on Pillar 2

DTL Recapture Rule in Pillar 2

Current and Deferred Tax Allocation under OECD Guidance

Remember Everything You Learn from Podcasts