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.
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.
OECD's Administrative Guidance on Pillar 2
The OECD releases detailed administrative guidance on Pillar 2, focusing on incorporating extensive commentary and adding clarity to rule operation. The guidance aims to assist jurisdictions in enacting and implementing the rules, addressing challenges faced by enacting countries.
DTL Recapture Rule in Pillar 2
The podcast sheds light on the complexities of the five-year deferred tax loss recapture rule in Pillar 2. The guidance clarifies the treatment of deferred tax liabilities that do not reverse within the stipulated period, emphasizing the impact on covered taxes and compliance burdens.
Current and Deferred Tax Allocation under OECD Guidance
The OECD provides comprehensive guidance on the allocation of current and deferred taxes in hybrid structures and across entities. By outlining specific methodologies and examples, the guidance aids taxpayers in understanding and complying with the rules, particularly beneficial for US multinationals and pass-through entities.
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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