Cross-border Tax Talks

Doug McHoney (PwC's International Tax Services Global Leader) and Jesse Kavanaugh (PwC Hong Kong’s Tax Reporting & Strategy Leader) met up at PwC’s AsiaPac Global Tax Symposium in Singapore. Jesse is an International Tax Partner in Hong Kong and has been leading the region’s Pillar Two tax efforts. They discuss the state of play of Pillar Two in Hong Kong, trends regarding safe harbours and data collection, modeling and calculations challenges, the centralized and decentralized approaches to Pillar Two inherent to the region, and the Hong Kong legislative process. They also touch on the addition of Hong Kong to the EU’s ‘grey list’ and the recent introduction of the Foreign Source Income Exemption (FSIE) Regime for Passive Income.

Doug McHoney (PwC's International Tax Services Global Leader) is back at Westminster Studios in St. Louis, Missouri where he’s joined by Steve Kohart, International Tax Principal with PwC in New York City and former Advisor for the Center for Tax Policy and Administration for the OECD. Together they discuss the latest wave of OECD Pillar Two guidance including the Subject-to-Tax-Rule (STTR), UTPR safe harbour, qualified domestic minimum top-up tax (QDMTT) safe harbour, marketable transferable tax credits (MTTCs), as well as the six key pieces of the substance base income exclusion (SBIE).

Doug McHoney (PwC's International Tax Services Global Leader) is joined by first-time guest Winnie Tang, International Tax Partner in PwC’s Financial Services practice in New York. Doug and Winnie take a rapid fire tour of the Financial Services and Deals space in light of the Pillar Two Transition Period, touching on the definitions of funds, REITs, excluded entities, management company structures, POPEs, Pillar Two in the Deals space, and many more particularities taxpayers should be aware of.

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s AsiaPac Tax Symposium in Singapore. He is joined by Michael Kim, a PwC International Tax Partner and South Korea’s Outbound Tax Leader. Doug and Michael discuss South Korea’s enactment of Pillar Two, paying particular attention to effective dates, likely legislative actions, the incorporation of future guidance, how taxpayers are preparing for Pillar Two, Safe Harbours, data collection, and covered taxes.

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s Global Financial Services Tax Leaders Meeting in Paris where he is joined by Will Morris, recently named PwC’s Global Tax Policy Leader. Together, they dive into the European Union’s Foreign Subsidies Regulation (FSR). They start with the origin story, how it intersects with State Aid, how taxpayers can be compliant, the necessity for collecting and saving data and information, consequences for failing to comply, and the challenges that taxpayers will face in the coming years, whether or not they currently do business in the European Union.

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Aaron Junge, PwC National Tax Services International Tax Partner, and former Tax Counsel for the House of Representatives during the enactment of the Tax Cuts and Jobs Act. They discuss the historical perspective of the Section 367(d) rules beginning back in 1984, the recent regulations, and how we got here. Doug and Aaron touch on Section 367(d)’s original intended purpose, how the changes that occurred during TCJA changed intangible property (IP) ownership for US MNC’s (the carrot and the stick metaphor), the possible tax treatments of the repatriation of IP, the applicability dates, and how taxpayers can prepare, while considering Pillar Two, among other areas.

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Edwin Visser, PwC’s European Tax Policy Leader. Prior to joining PwC, Edwin was the Deputy Director General for Tax Customs Policy and Legislation and Director for Direct Taxes at the Dutch Ministry of Finance. One of the real challenges for tax professionals and advisors is the sheer volume of tax proposals from the European Union. Edwin and Doug discuss the numerous EU tax proposals, including the Carbon Border Adjustment Mechanism (CBAM), the Foreign Subsidies Regulation (FSR), Green Energy Credits, ATAD3. They also cover the EU’s legislative process, flashback to the Common Consolidated Corporate Tax Base (CCCTB), then tackle Business in Europe: Framework for Income Taxation (BEFIT), the SAFE project, and the Debt-equity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two.

Doug McHoney (PwC's US International Tax Services Global Leader) hosts Matt Ryan, London-based International Tax Partner and leader of PwC’s UK Pillar Two Ready Team. Doug and Matt discuss the second draft of the UK’s Pillar Two legislation, the probable timing of enactment, the accounting implications, the UK’s Qualified Domestic Minimum Top-up-Tax, and some of the ‘deviations’ in the UK rules.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice. Pat has previously worked in the private industry for 16 years, including several years as a VP of tax and director of tax policy. After Pat chooses his most and least favorite CBTT podcasts, Doug and Pat discuss green energy credits, the Pillar Two Model Rules and administrative guidance, how the US and UK R&D credits compare under Pillar Two, refundable credits, transferable credits, the equity investment inclusion election, and qualifying flow-through tax benefits.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Shin Yamaguchi at PwC’s 2023 International Tax Conference. Shin is a Tokyo-based International Tax Partner, where he leads PwC Japan’s Inbound Tax Practice. Doug and Shin discuss Japan’s latest tax developments, focusing on the Pillar Two rules (of course!), specifically, UTPR, IIR, Safe Harbours, QDMTT, the GloBE Information Return and effective dates. They also discuss the Japanese legislative process.Since the recording of this podcast Japan has enacted their 2023 Tax Reform Bill which includes the Pillar Two Income Inclusion Rule which applies on or after April 1, 2024.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Craig Stonberg at PwC’s 2023 International Tax Conference. Craig is PwC’s Macro Intelligence Leader, and spearheads a team of analysts helping global businesses with geopolitical risks, macroeconomic volatility, and supply chain shifts. Doug and Craig discuss the geopolitical landscape, particularly in Asia and Europe; how a recession would affect multinational companies, the labor shortage that is particularly affecting women, the geopolitical part of the energy equation, and how multinational companies should be preparing for 2023 and beyond.

Doug McHoney (PwC's US International Tax Services Global Leader) is back in Westminster Studios with Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice. Doug and Kate discuss what is meant by Pillar Two operational readiness and PwC’s Data Input Catalog, including the data requirements, the necessity of resources, the Data Input Catalog, safe harbours, ERP and enterprise systems, the importance of working as a team, how software tools can help, and the power of a centralized rules engine.PwC’s Data Input Catalog

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Phil Ramstetter, PwC International Tax Partner based in Chicago. Phil was formerly a tax policy consultant for Business at OECD (BIAC). Doug and Phil overcome conference background noise to discuss the recent administrative guidance, but start with a history lesson on Pillar Two, when it was merely the Digital Project. Topics covered include blended CFC regimes, GILTI, expense apportionment, loss-making jurisdictions, transition period transactions, common control, the outlook for future guidance and some of the remaining open questions.

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Pascal Saint-Amans, former Director of the OECD's Centre for Tax Policy and Administration and current partner with Brunswick, a strategic advisory firm. Doug and Pascal dive directly into the BEPS Project with an overview of the Pillar Two origin story, the challenges and successes of the project, harmful tax practices and the ways the OECD is trying to change tax systems, the natural complexity of tax, the future of tax incentives, compliance requirements, the private sector’s role in the policy process and much more.