Following a landmark OECD/G20 statement and implementation plan announced on October 8, 2021, multinational companies are now facing a global minimum corporate tax on their operations with multilaterally agreed limitations on said tax. The implementation plan at national levels, known as Pillar Two, seeks to address the tax challenges arising from the digitalization of the economy and was endorsed by G20 Finance Ministers and Central Bank Governors at their October 2021 meeting.

Such was the backdrop and main focus of USCIB’s 15^th annual OECD International Tax Conference at the Four Seasons in Washington DC earlier this week (June 27-28), where more than 200 tax experts, OECD officials, multinational companies, as well as foreign and domestic government representatives gathered for the two-day event to discuss pressing global tax issues and developments, including Pillars One and Two.

“This conference took place at another critical point in the 2022 OECD timeline for designing Pillars One and Two for consensus in the Inclusive Framework and, eventually, implementation at the national level,” said USCIB Vice President and International Tax Counsel Rick Minor.

According to Itai Grinberg, deputy assistant secretary for multilateral tax office of tax policy at the U.S. Treasury, ““Pillar Two helps level the playing field. It will ensure that all U.S. and foreign headquartered MNCs face a common level of minimum taxation. And in doing so, this deal, as it has come to be, really answers the single most frequently heard international tax policy request made by the U.S. multinational business community for the entire course of the 21^st century.”

“The stability of the international tax architecture is at stake here,” said Martin Kreienbaum, director general of international taxation at Germany’s Federal Ministry of Finance. “I think the international tax architecture is the predictability of tax burden for tax payers from a tax payer perspective. But it’s also the avoidance and absence of double and multiple taxation. I think that is the main objective, the main purpose, under which we have the discussions in the inclusive framework.”

Many questions still remain around Pillar One however, especially in terms of better multilateral coordination around multiple and double taxation and how to build trust with tax payers.

“Together with the agreement on October 8, we had a detailed implementation plan with an extremely ambitious political timeline,” reflected Pascal Saint Amans, Director of the OECD Center for Tax Policy and Administration. “Keep in mind that the overall debate and the deal was still concluded against the background of transatlantic tensions with the previous administration and the need to show that we are restoring better relationships among the countries at stake and cooling down on threats of multilateral measures or trade sanctions.”

Other panels during the conference focused on the tax implications of an increased global mobility of workers arising from the pandemic, tax and climate change, a global minimum tax, dispute prevention and resolution, and much more.

USCIB members from Deloitte, Google, Procter & Gamble and Ernst and Young, among others, joined as panelists to contribute their companies’ perspectives on these pressing taxation issues.

More information on the agenda, speakers, and topics of discussion can be found here.

USCIB is the national affiliate of Business at OECD (known as BIAC), the official multi-jurisdictional business advisor the to OECD.

Featured speakers included:

• Grace Perez-Navarro – Deputy Director, Centre for Tax Policy and Administration, OECD
• John Peterson – Head of Unit, Aggressive Tax Planning, OECD Centre for Tax Policy and Administration
• Achim Pross – Head of International Cooperation and Tax Administration Division, Centre for Tax Policy and Administration, OECD
• Pascal Saint-Amans – Director, Centre for Tax Policy and Administration, OECD
• Rick Minor – Vice President & International Tax Counsel, USCIB
• Itai Grinberg – Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury
• John Hughes – Director of Field Operations, Northeastern Compliance Practice Area (Mid-Atlantic) (LB&I), IRS
• Rebecca Kysar – Counselor to the Assistant Secretary for Tax Policy, U.S. Treasury
• Michael Plowgian – Co-Chair, OECD Task Force on the Digital Economy and Counsellor, Office of Tax Policy, US Treasury
• Isaac Wood – Attorney-Advisor, Office of Tax Policy, US Treasury
• Martin Kreienbaum – Director General, International Taxation, Federal Ministry of Finance, Germany
• Fabrizia Lapecorella – Director General of Finance of the Italian Ministry of Economy and Finance and Chair of OECD Committee on Fiscal Affairs
• Gaël Perraud – Co–Chair, OECD Task Force on the Digital Economy; Director of International Taxation and European Affairs, Ministry of Economy and Finance, France
• Mike Williams – Director, Business and International Tax, HM Treasury, United Kingdom
• Barbara Angus – Global Tax Policy Leader, Ernst & Young LLP
• Mary Bennett – Senior Counsel, Baker & McKenzie
• Ryan Bowen – Senior Manager, Washington National Tax Office, Deloitte
• Nate Carden – Partner, Skadden
• Liz Chien – Global Head of Tax and Chief Tax Counsel, Protocol Labs Inc.
• Tracee Fultz – Global Transfer Pricing Leader, Ernst & Young LLP
• John Harrington – Partner, Dentons US LLP
• Hannah Hawkins – Principal, KPMG Washington National Tax, KPMG
• Harris Horowitz – Managing Director, Global Head of Tax Policy & Innovation, BlackRock, Inc.
• Tom Hutchinson – Vice President, Finance, Google
• Mark Martin – Principal, Washington National Tax, KPMG
• Tim McDonald – Chairperson, USCIB Tax Committee and Senior Vice President, Finance & Accounting, Global Taxes, The Procter & Gamble Company
• Alan McLean – Chairperson, Business at OECD Committee on Taxation and Fiscal Affairs and Executive Vice President, Tax and Controller, Shell International Limited
• Will Morris – Deputy Global Tax Policy Leader, PwC
• Loren Ponds – Member and Co-Lead of the Tax Policy Practice, Miller & Chevalier
• Tom Roesser – GM, Tax Policy Counsel, Microsoft
• Danielle Rolfes – Co-Partner in Charge, Washington National Tax-International Tax, KPMG
• Sonja Schiller – Head of Global Tax Controversy, Netflix
• Daniel Smith – Director, International Tax Planning & Policy, Google
• Liz Stevens – Member, Caplin & Drysdale
• Bret Weaver – Partner, KPMG
• Louise Weingrod – Vice Chairperson, USCIB Tax Committee and Vice President, Global Taxation, Johnson & Johnson
• Lisa Wolski – Head of Government Affairs and Senior Executive Counsel, General Electric