International Tax - An OECD Pillar Two Update

Introduction

Join Jivaan Bennett of Linklaters who will provide a review of the current Pillar Two elements and framework and together with a status update and key issues for practitioners.

What You Will Learn

This webinar will cover the following:

• The Pillar Two elements
• Recap - the Pillar 2 Framework
• Two domestic law rules
• An ‘income inclusion rule’ (IIR)
• An ‘undertaxed payments rule’ (UTPR)
• An international treaty‐based rule: a ‘subject to tax rule’ (STTR)
• Key elements of the draft model rules
• Scope
• Key operative rules
• Charging Provisions
• Computation of GloBE income or loss
• Computation of Adjusted Covered Taxes
• Computation of Effective Tax Rate and Top-up Tax
• Status Update - where are we now?
• Implementation
• Model rules
• A multilateral instrument
• An implementation framework
• Key Issues for Tax Practitioners
• Pillar 2 Issues in the context of cross-border transactions
• Conclusions and prospects