Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Tax Symposium in Rome, where he’s joined by Will Morris. Will is PwC’s Global Tax Policy Leader, and on Will’s last visit to the podcast, he covered FSR, the Foreign Subsidies Regulation. On this podcast, an exciting and familiar topic Pillar Two! Doug and Will discuss generally how the Pillar Two process has been going. They wonder how tax authorities and courts will administer and adjudicate in their jurisdictions, and what will become of the potential FAQs and future administrative guidance from the OECD. They then discuss the recent EC guidance, and whether countries will be able to bring in the OECD guidance retroactively. Finally, Doug and Will touch on how business have participated thus far in the process.

Timestamps:

1:41 Will joins Doug in the YouTube game with the launch of Global Tax Talks!
4:05 Will provides his thoughts on Pillar Two, and how the Pillar Two process is going.
9:40 How are tax authorities, jurisdictions and courts going to administer Pillar Two? How will the Pillar Two FAQs get incorporated into domestic legislation?
17:35 The South Korea issue: Could they impose the UTPR on the rest of the world?
21:08 What was in the recent European Commission Administrative Guidance? What did it say about the Market Transferable Tax Credit?
24:52 Will countries enacting in 2024 be able to bring the Administrative Guidance into their legislation retroactively? Is the US R&D tax credit fair game for the IIR?
26:58 what about potential for more safe harbors, especially for US or other incentives?
31:20 How are businesses participating in the Pillar Two process?
37:01 Will’s article in Bloomberg “Tax and ESG: Reporting is a growing, undervalued relationship”