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PwC's Tax Bites Podcast

Pillar 2 and the US Tax Regime

PwC's Tax Bites Podcast

PwC Belgium

Legal, Business, Workforce, Bites, Tax

5.01 Ratings

🗓️ 4 July 2025

⏱️ 24 minutes

🧾️ Download transcript

Summary

The global tax landscape just took a major turn. In our next episode, Pieter and his guests dive into the G7 agreement that would exempt U.S.-parented multinational groups from the Pillar 2 Income Inclusion and Undertaxed Profits Rule. In return, the U.S. has agreed to drop the proposed Section 899 from the so-called “One Big Beautiful Bill”. Tune in for a concise breakdown of what this means for multinationals and the future of Pillar 2. Have a look at all our previous episodes and stay up t...

Transcript

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0:00.0

Hello everyone, welcome to PWC Taxbyte podcast series.

0:08.5

My name is Peter and I'm very happy that I can welcome you to this next episode.

0:12.8

It's been a little bit since the last episode that we recorded, but we are back here because a lot is moving in the international tech space.

0:21.5

And today I particularly want to talk about Pillar 2, G7 and US tax policy.

0:28.0

And for that I have with me, Evie Geertz, a partner in our group here in Belgium,

0:32.9

focusing on the US pillar 2 international tax, so the right person to have in this recording studio.

0:39.7

And also Maxima L.R., director in our team, focusing on Pillar 2, connecting that with the complexities of the compliance around Pillar 2.

0:48.0

So I would say the right people in the room to have a discussion on this.

0:52.4

And the reason I wanted to issue this podcast is basically the G7 statement.

0:59.3

As many of you have probably heard, there was a statement of the G7 on Pillar 2.

1:05.8

And this is going back to the enactment of President Trump, the statements, the withdrawal from Pillar 2 by the US.

1:15.2

And then in the past months, the discussions around imposing Section 899, a kind of huge pressure

1:23.1

in the US legislation to come to an agreement with US and the European Union

1:28.9

to solve the tensions on Pillar 2 and the uncertainties around that

1:32.8

and that ended then in this statement of the G7

1:36.9

initially announced on social media formally published on the 28th of June

1:41.7

and this G7 statements basically puts forward an agreement to

1:47.3

come to a side-by-side system on Pillar 2. And in this podcast, I would like to explore a little bit

1:53.9

what this all means and what the impact is for Pillar 2. First of all, a side-by-side system,

2:00.5

what does it mean? Well, it means that U.S. mult of all, a side-by-side system. What does it mean? Well, it means that US multinationals

2:05.1

will be exempt from the Pillar 2 income inclusion rule. So the rule that basically, from a

2:12.2

headquarter perspective, taxes the entire group under the minimum taxation and the UTPR.

...

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