Chand, V.

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Serveur académique lausannois

1Kluwer International Tax Blog - 1 / 3 - 02.11.2021Kluwer International Tax BlogPillar II podcast: Are minimum taxes the future?Vikram Chand  (Managing  Editor)  (Tax  Policy  Center  of  the  University  of  Lausanne,Switzerland) · Thursday, March 11th, 2021Welcome to the second tax post in the series of International Law Talk. During a seriesof podcasts, Wolters Kluwer will bring you the latest news and industry insights fromthought  leaders  and  experts  in  the  field  of  International  Arbitration,  IP  Law,International  Tax  Law and  Competition  Law.  Here  at  Kluwer  Tax  Blog,  we  willhighlight the podcasts focused on international tax.In the second tax podcast of the series, Professor Vikram Chand, Managing editor ofKluwer Tax Blog, interviews Bob Stack, who is a Deloitte Tax LLP managing directorin Deloitte’s Washington national tax/international tax services group.The Pillar II issue is well known by now. The proposal put forward by the OECD,among other points,  seeks to establish a minimum global effective corporate tax rate.In other words, when a company which belongs to an MNE operates in a country andits effective tax rate (ETR) is below the globally agreed minimum rate then a complexset of rules will kick in and reallocate income to other jurisdictions. The re-allocationswill  apply  pursuant  to  the  income  inclusion  rule  (IIR)  or  /  and  the  undertaxedpayments rule (UTPR). Thereafter, the jurisdiction to which the re-allocation is madecan tax the income on the difference between the globally agreed rate and the actualETR.2Kluwer International Tax Blog - 2 / 3 - 02.11.2021Wolters Kluwer recognizes the importance of this topic and have arranged a podcastbetween two leading experts in the field of International Taxation and Transfer Pricing andmore broadly  international  tax experts  who have deep knowledge on the Digital  TaxDebate.In this podcast, the following topics are covered:Where is corporate income taxed under the current international tax framework?What  issues arise when corporate income is taxed in a State where an enterprisehas its production factors ?The  shift  from  restricting  harmful  tax  competition  to  restricting  genuine  taxcompetitionThe scope of Pillar II – Is it more principled than Pillar I?The key issues with respect to determining effective tax ratesThe US GILTI and the IIRThe under-taxed payments rule – Is it justified? Comparison with the US BEAT andAnti Hybrid RulesUS GILTI (global blending) vs IIR (jurisdictional blending): What trumps what?http://kluwertaxblog.com/wp-content/uploads/sites/59/2021/03/KLI-9-trailer.mp4 Our previous blogs on the topic can be found here:–http://kluwertaxblog.com/2021/03/01/is-there-a-leak-in-the-oecds-global-minimum-tax-proposals-globe-pillar-two/–http://kluwertaxblog.com/2020/11/06/the-pillar-two-mechanism-in-light-of-the-blueprint-a-case-study/—http://kluwertaxblog.com/2020/09/18/pillar-ii-of-the-digital-debate-our-view-on-the-approach-towards-blending-and-substance-carve-outs-to-determine-effective-tax-rates/ Please click on the link below to hear our podcast: Listen to the discussion  ________________________3Kluwer International Tax Blog - 3 / 3 - 02.11.2021To make sure you do not miss out on regular updates from the Kluwer InternationalTax Blog, please subscribe here.This entry was posted on Thursday, March 11th, 2021 at 5:31 pm and is filed underEffective Tax Rate, GILTI, IIR, OECD, Pillar II, United StatesYou can follow any responses to this entry through the Comments (RSS) feed. You canleave a response, or trackback from your own site.

Pillar II podcast: Are minimum taxes the future?

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Pillar II podcast: Are minimum taxes the future?

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Serveur académique lausannois