Cross-border Tax Talks Podcast | PILLAR TWO POTPOURRI: WHERE IS THIS HEADING? | Pat Brown

Doug McHoney (PwC’s International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school. They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations’ role in international tax, and recently published Belgian Pillar Two registration requirements.
Timestamps:
1:40 - How complex is the international tax system as a whole, today?
6:27 - What role does Pat see the United Nations playing in the tax landscape?
9:26 - In 2025 the UTPR is going to kick in. What should taxpayers be thinking about as it looms very, very large?
19:15 - What are the biggest concerns for businesses in regards to Pillar Two provisioning and compliance?
25:14 - Kudos to the OECD for its publication of the consolidated commentary to the global anti base erosion model rules
26:31 - Changes to incentives: Where are we heading in the competition for foreign direct investment?
33:18 - What is Pat’s reaction to Belgium’s Pillar Two registration requirements published on May 29, 2024?
36:40 - With recent OECD guidance on CbCR in May, what should taxpayers be aware of?
40:50 - Pat’s reaction to Secretary Yellen’s comments to the US House Ways and Means Committee regarding the Two Pillar Solution.