Pillar Two model rules

PwC's Tax Bites Podcast

PwC Belgium

Bites, Business, Workforce, Legal, Tax

5.0 • 1 Ratings

🗓️ 16 March 2022

⏱️ 20 minutes

🔗️ Recording | iTunes | RSS

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Summary

On 22 December, the European Commission issued 2 proposals. One proposal deals with the introduction of the global minimum tax in the EU by 2023. The EU proposal deviates from the OECD proposal on a number of topics. Find out how the proposal will look like in this Tax Bites episode with Jean-Philippe van West and Isabel Verlinden. In addition, we also discuss the proposed directive covering the ‘unshelling’ of the EU: the proposed ATAD 3, or should we say, ‘new DAC’. Let us know what y...

Transcript

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0:00.0	Hello everyone. Welcome to the PWC Taxby Podcast series. My name is Peter Drey and I'm sitting here in my virtual recording studio with Jean-Filippe Van West, a senior council in our team.
0:17.2	And yeah, Jean-Filippe, we're sitting here because today could have been a historic day.
0:22.0	And we're also sitting here with a big pile of paper.
0:25.4	Because we're going to talk about the pillar two and the developments around pillar two in Europe and at OECD level.
0:33.6	Today could have been a historic moment. Indeed, there was an ECOFIN meeting and the French Presidency was pushing to get an unanimous agreement on the draft text on the Pillar 2 implementation in Europe.
0:45.3	What we have heard for now in the media is that that historic moment has not crystallized today.
0:51.3	A number of countries stay against the current draft text of the
0:56.8	proposal. For instance, Sweden wants a bit more time to get an agreement. Some smaller
1:02.8	countries we hear still want even more flexibility to implement the rules. So basically
1:08.9	they want a delay to implement the rules.
1:11.9	And the current draft text already provided for the option to have a five-year delay of
1:17.5	implementing the rules. But apparently some countries are not accepting that.
1:22.8	And yeah, it was a good attempt of France to get an agreement, but at this moment there is no agreement.
1:30.3	But still, Jean-Philippe, we have a lot to talk about. It's a historic development the past days, I guess.
1:37.3	Yes, indeed, Peter. And let me start with the beginning and what happened at the beginning of this week on
1:45.4	Monday so on Monday the OECD published the long expected commentary to the OECD pillar two model
1:54.8	rules this is a quite lengthy document there so the commentary itself is 228 pages and is accompanied by a document with examples of
2:04.9	approximately 50 pages. So together a lot of materials to read. What is important there is that
2:14.6	the where the commentary, the commentary to the Pillar model rules is approved by the OSD G20 inclusive framework.
2:23.3	It was approved on 11 March of 2022.
2:27.3	However, if you look at the document with the illustrative examples, there you read that it was prepared by the OECD
2:35.4	secretariat and did not seem to have received the approval of the inclusive framework. So
	...

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