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 Debtequity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two.

Timestamps:

2:50 Can you explain the EU CountrybyCountry Reporting (CBCR) directive?
6:00 What about the Carbon Border Adjustment Mechanism (CBAM)?
8:00 What is the context for the Foreign Subsidies Regulation (FSR)?
10:45 What are the consequences if a taxpayer is doing a deal and takes advantage of certain incentives as defined by the FSR rules?
12:00 How do taxpayers know what incentives could potentially be triggered under FSR?
12:45 Can we expect the EU to provide a list?
15:15 Moving on to the Antitax Avoidance Directive, what is ATAD3?
18:15 How do they define a ‘shell company’?
21:25 What is required to pass an EU directive?
22:40 Moving on to the Business in Europe the Framework for Income Taxation (BEFIT) is it fair to call this the Common Consolidated Corporate Tax Base (CCCTB) 2.0 or is that an oversimplification?
25:30 Where is the EU in the process of enacting a BEFIT proposal?
30:30 What is SAFE Securing the Activity Framework of Enablers?
33:50 How will the upcoming EU elections impact tax policy and initiatives?
35:15 What is DEBRA?
36:25 Where are we on Pillar One?
38:15 What about the compatibility of Pillar Two and EU law, given that we already have an EU directive passed?
40:20 What is the legal process if a taxpayer were to contest the compatibility of Pillar Two and EU law?
44:35 Any general advice for taxpayers in the current international tax climate?




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