[Music] This is Guilty Conscience, casual discussions on transfer pricing, tax treaties, and related topics, a podcast from Scadden that invites thought leaders and industry experts to discuss pressing transfer pricing issues, international tax reform efforts, and tax administration trends. We also dig into the innovative approaches companies are using to navigate the international tax environment and address the obligation everyone loves to hate. Now, your hosts, Scadden Partners David Farhat and Nate Carter. Hi, everybody. Nate Carter here, once again with David Farhat. Stefan Victor, Iman Kyler. This is Guilty Conscience. Today, we're going to revisit Pillar 2. We're joined by Vikram Chand, professor at the University of Lausanne. Vikram, welcome to the show. What's going on with Pillar 2? What are the latest updates? Thanks, Nate, for this question. A lot of updates on the Pillar 2 side. To put it across very simply, many countries are signing up to the Pillar 2 initiative. If you take the common law space, you have the UK, which has already released the draft legislation.

addition to UK, you have Canada, New Zealand, um, as well as Australia who have already launched draft consultations within the European Union. The European directive has already been passed on pillar 2 so we could expect a pillow 2 to come in um in actually into the legislation of a lot of European member states in um 2024 at maximum by 2025. In Asia, a lot of countries are signing up again to the pillar 2 Initiative. For example, Japan, Korea, Malaysia, most likely Indonesia, maybe in the future India too. And within the African Union, um, the African Tax Administration has already released the draft legislation for qualified domestic minimum Top-Up taxes which is an integral part of the pillar 2 system. Um, not on the income inclusion rule, not on the utpr, but on qualified domestic minimum Top-Up taxes. So that's just a global update but in addition to all these countries historically all the low tax countries like Switzerland, or Hong Kong, or even Jersey, they have announced adoption of the pillow 2 initiative. So Vikram what happened last I remember.

folks were kind of pessimistic as to if this would take a hold or move forward. What happened to have this turn where now it seems to be a universal acceptance of this outside of the U.S.? Well, actually, I think a lot of countries were interested in adopting this legibility legislation already. But what really triggered so many countries to move ahead right now is basically the European directive. So, since all the European member states agreed to this directive, and now the directive is coming out, we see that around 27-28 European member states will be introducing these rules. So, all the rest of the world outside the US is actually going to follow. Why is Europe so hot on this? What's the overall dynamic? Well, actually, if you look into the countries which are actually pushing for a minimum tax rules, apart from the US which already had the U.S. guilty, it was actually Germany and France and some other developed countries within the European region too, or the big countries as I like to call them.

were pushing for this initiative. And, um, well, uh, it's a success. Now, these countries got what they wanted. But what was the primary concern that they had in the first place? Things seem to be going reasonably well, at least as I see it, for a lot of these countries. They were economically successful. What's the problem that they're ultimately trying to solve? And does pillar 2 really solve it? Well, actually, the problem that they were trying to solve was initially to combat remaining bets issues, um, whatever that meant. Nobody knows what the remaining depth issues were, but the way the project has progressed and developed, it's quite obvious. It acts as a tool to restrict tax competition among member countries. But does it success? Does it achieve this objective of restricting tax competition? Or let's say it's not. It's restricting tax competition by creating a floor up to 15. But is this project actually achieving that? Well, on one hand, on the face of it, you can just say yes, it's achieving a minimum floor of 15. But on the other hand, there are some provisions within

the pillar two model rules, which still permit countries to continue with tax incentives, are basically known as qualified refundable tax credits. So right now, there's a big debate outside the U.S., I guess within the U.S. also, is how can you reshape your existing tax incentives or how could you come up with new tax incentives, and you make them compatible with something known as the qualified refundable tax credit system in the pillar two rules, so that you can still continue offering tax incentives to large multinational taxpayers as well as small and medium Enterprises. So on the one hand, on the face of it, it looks like the project will achieve its goal, but when you take a deep dive into the rules, you see that you can still achieve a very low tax rate as long as you have compatible in, you know, the incentives that are being offered by governments are compatible with the pillar 2 framework. So is it fair to say then that pillar 2 is not really about getting rid of tax competition generally?

it's just reshaping tax competition to the playing field. That certain countries like where they can pick winners and losers. For me, the answer is yes. So what pillar 2 is doing is shifting the tax competition landscape. Yeah, you don't compete on the rates anymore. You will compete on the kind of incentives, which um, which countries can actually design. And once again, as long as they are qualified in nature. Now the question is who's going to certify whether these incentives are qualified or non-qualified. But once again, it has to be certified by the OECD's inclusive framework through the spear review mechanism, which has been taking place since a long period of time. Whether it's in the best Section 5, which dealt with harmful tax regimes, web section 6, which dealt with treaty abuse, there was several peer review mechanisms that the OECD came up with. So all this qualified nature of these rules will also be discussed in this through the spear review mechanism. So a lot of power will also be shifted back to the OECD's.

inclusive framework to decide whether or not a country has an appropriate tax incentive regime or not. We talked about problems that pillar 2 is designed to fix, and we're kind of talking about does it fix those problems or does it do something completely different. And you mentioned, um, kind of these lingering issues that perhaps 1.0 didn't address. Do you think the tax community or the international community as a whole gave BEPS 1.0 enough time to work, gave folks enough time to kind of work through those principles to see if they really worked, or do you think there may have been just a rush to, uh, to BEPS 2.0? Well, honestly, uh, the countering tax competition wasn't even on the BEPS agenda because if you look into BEPS Section 5, which basically introduced the substantial activity requirement, there was a clear statement in this Action 5 report that will basically say that, well, uh, the objective of BEPS Section 5 is not to dictate a country what the tax rate should be.

just to ensure that countries have the appropriate substance, or they have regimes which with the appropriate substance, yeah in them so though so there was never this motive to restrict tax competition and actually the only pending webs issue was on best section one. The pillar one project, which is, uh, which apparently is not going anywhere at this stage, uh, because a lot of academics, you know, I'm still, I'm still fascinated by the pillow one project of the OECD. I have to confess this amount a system, but a lot of academics in the European region, they've already said they've declared this project to be dead, but the discussions keep progressing at the level of the OECD, and recently some new estimates were released by the OECD saying that pillow one is actually going to reallocate much more than that was initially imagined, almost double. You're talking about 200 billion, uh, US dollars or something like that if I remember correctly. So that was the remaining bets issue, which was on reallocation of taxing rights, but we don't know whether that project.

is going to be successful or not at the end of the day. Vikram back to your point about the certification process and the review panel for credits and other pillar 2 implementation rules. Tell people who may not be as familiar with the way European domestic regimes work, how does that overlap with European domestic law. So, if I'm a company in Europe and I think the inclusive framework has made a mistake, I think that the credits that I'm getting should be treated as qualified. Who do I complain to? Well, let's just take a few steps back here. Now, when you're talking about tax incentives, now tax incentives can be actually income-based incentives or expenditure-based incentives. But now income-based incentives, incentives which you basically see in developing countries. So just to give you a few examples, Indonesia, India, a lot of African countries, they just have income-based incentives which basically says that well, if you have a profit, we'll just exempt you from taxation or your tax rate is not going to be the full rate. Is this going

to be half uh you just pay taxes on half the amount so that's very simple and easy to administer um. When you talk about income-based incentives on the other hand, the developed countries in the world um, including the US, which I assume have expenditure-based incentives typically in the form of tax credits. What, what are tax credits just for people outside the U.S to know is that basically you can use these credits to set it off against your normal corporate income tax payable or it can be used for payment of any other taxes. So many countries currently like the UK and France, they have expenditure-based incentives or are linked to R&D expenses. What does that basically mean? That means that if the taxpayer, a company, a French company or a UK company, they have let's say 100 of expenses on research and development, then a certain percentage of that, let's say if 10 was the tax credit that the taxpayer is entitled to, so 10 would be the credit. And then assuming at the end of the day you have a couple

income tax liability of 15. You can use that 10 to set it off against your corporate income tax liability. The issue with R&D tax credits is that they are quite difficult to administer because you really need to develop a big list of, uh, to understand what kind of expenses, uh, are eligible R&D expenses. And, uh, these incentives from the government side, too, they take a lot of time to administer. So basically, now when countries start offering all these incentives, there's going to be a body who has to certify whether or not these credits are qualified in nature. And that's the OECD's inclusive framework. De facto, you give substantial power back to the OECD's inclusive framework to decide whether a country has a good incentive or a bad incentive, um, or not. And as you all know, that the biggest funders of the OECD, including the US, are the developed countries, so they will start dictating, um, tax policy or tax incentives, which other countries will need to adopt. Is that typically allowed under European

domestic law, because in the United States, for example, there would be serious constitutional issues if the Congress said, Hey, we're going to allow these unelected people at the OECD to issue binding rules that taxpayers couldn't challenge. Well, actually, in the EU context, European law takes precedence over the national law of different member states. So, European law ranks at a higher pedestal than national law. And here, the European legislators, the EU Commission, have passed the directive, and the directive is actually binding on all member states. So, all the member states will need to comply with what's written in the directive. And the directive basically, the government's, I would say, 80% or 85% of the directive, the copy-paste of the OECD model rules. So, essentially, all European member states are bound by the directive right now. But what about the inclusive framework determinations, right? In other words, has the directive also delegated to the inclusive framework will follow you no matter what you do, and is that permitted under European law? Well, that's a big

debate right now in uh within the European Union is what is the legal status not only of what you just mentioned but also the legal status of the oecd's commentary on the pillar 2 rules. What is the legal status of that? If you look into the directive, the European directive says that all the outcomes of or the rules of which have been outlined or written in the directive, they need to be interpreted in light of the oecd commentary. So, there are some references to the oecd commentary uh in the directive itself. So, the directives uh somehow uh gives a lot of power to the oecd commentary on the pillar 2 rules. But when it comes to determinations of whether a rule is a qualified rule or not, um, whether it's a qualified domestic minimum type of tax or it's a qualified refundable tax credit, so on and so forth, you know it looks like the directive has given the powers to the oecd's inclusive framework. But till what extent that it can be done with the European law

framework. It's still ongoing. There's still an ongoing debate on this topic and will this get litigated in European courts. Should we stay tuned or how does this work out well that's also a big question right now because um the questions are the question one one question that was raised in a discussion recently in another panel I was a part of was basically till what extent can um can taxpayers challenge the directive provisions before the European Court of Justice because um it because you see the directive sometimes the directive says one thing but you know the way the directive has been transposed into the member states national law could be there could be slight differences or variations and then the question then becomes in can the taxpayer basically tell the national member state that well you know the rules you didn't really apply were in conformity with the directive so basically then they start challenging the national law rules before courts. It's well possible yeah it could well be possible that they do that because if you look into the recent administrative

guidance that was released by The OECD. A lot of discretion is given to member states, um, or let's say to the OECD's inclusive framework when it comes to implementing these qualified domestic minimum top of taxes. A lot of discretion has been given, so if, if I'm listening to you, it sounds like not much is going to change. It's just going to get more complex. It's going to get super complex, yeah, because the way you have to calculate this 15 effective tax rate is, uh, is quite complex and, um, well, like I mentioned to you, you have one, one stream of the IIR and UT-P-R stream and the other stream is QDM-TT. There are a lot of similarities between this, between both these streams of rules, uh, but at the same time, now after reading the administrative guidance, you can see there are so many differences. And one classic example there is of allocation of CFC taxes. I'm not talking about the U.S. guilty for a minute, but if you see for IIR and UT-P-R purposes, there was an

agreement among countries. Whenever a state of residence applied its CFC Rule and collected taxes for its CFC through the CFC rule in its home state, these CFC taxes paid in the home state, they had to be pushed down for the ETR calculations of the sub. One question that I struggle with is in the design of the rules and curious to your perspective on qdmtt design. Why doesn't qdm TT just turn off iir and utpr? As I read the rules, it's not designed to operate that way. Why not? Well, actually, right now there's a big debate within the inclusive framework of something known as qdmgt say father. So basically, if you just recently, the OE released a report on Save fabers where they spoke about temporary safe hours and permanent safe hours. But in the future, there's also they are contemplating on introducing something known as a qdm GTC fiber. If my understanding is correct of what they mean by a qdmdt say father is just that.

if you have, let's say, a German parent with a sub in Singapore, and the Singapore sub is basically exposed to QDM TT. Or, Singapore has an appropriate QDM QDM GT in place, then basically, the German parent will not have to do any IIR calculations for this sub in Singapore. The top of tax will be deemed to be zero when, for the purposes of the income inclusion rule. So that's probably that will come out. That's something that may come out in the near future, QDM GT save Faber. So that's the thing until the German government decides that Singapore's domestic minimum top-up tax isn't qualified, and then they assert that the German company owes additional tax. Yes, so that's the problem, you know. Once again, what is the legal nature of all these qualifications? Because if the qualifications may, some qualifications could be done by the OECD's inclusive framework on whether a country has a qualified rule or not. But is that really binding on the local tax administration, the German Tax?

Administration in our simple example here. I don't know the answer to that. I don't think so, actually. How can something which is being decided in Paris be binding in Germany? Are definitely not for in the in in the court system. What's the impact of all of this to the current treaty system and treaty networks? Well, uh, there's a big debate right now, uh, which hopefully you will have heard, is whether the pillar two rules breach tax treaties. And now when I talk about the pillar 2 rules, I'm just here talking about the income inclusion Rule and the uh on the tax profit rule. Uh, I think a lot of governments, they are of the opinion that the income inclusion rule does not really conflict with tax treaties because it's just like a super CFC rule. Um, but at the same time, actually, I wrote a very big paper with a couple of co-authors where we said that probably the income inclusion rule can also conflict with tax treaties. I don't know how successful that would be, but yeah.

we've written a big paper on that, but clearly when you talk about the under-taxed profit rule, that's extra-territorial taxation for me. Uh, for that, for me, it's just obvious this conflicts with tax treaties. Um, I know there's a few legal scholars. It was a recent paper I read of an American scholar who said this is like an excise tax. It's outside the scope of tax treaties. That's not true. It's this is not true. It's an income tax. It's a tax on corporate profits. Um, a system book minimum tax. It's a substantially similar death for the purpose of tax release. So if it's covered by tax treaties, then um, I'm pretty sure that once countries start enacting the UTPRs or they want to enforce their UTPRs, a bunch of taxpayers, they're just going to go to court and say this is extra-territorial taxation and this needs to be and treaties basically prohibits such extra-territorial taxation. It looks like just from our discussion so far there are a

lot of questions that still need to be answered but for in-house lawyers listening and just multinationals generally what should they be doing right now. Should they try to assess their burden I mean the compliance uh for the future. Should they try to determine if they are in scope now or if they'll be in scope in the future or should they just wait and see until all of this is sorted out to start planning. Well actually to be honest I think you're all your clients or multinationals in general this it's not only multinational review of what we're talking about just to let you know even you're talking about private owned businesses which are more than 750 million of turnovers. So recently uh structure was shown to me through foundations and the question was whether this structure which was run through a foundation or trust was caught by the pillar two rules and answer was yes it was caught by the pillar two rules um uh so is so essentially it's not only for multinationals it's also for large

privately owned businesses who of course they need to start doing the assessment because these rules are going to come in um like it or not. These rules are coming and the European Union has passed a directive and more and more countries are adopting these rules um in 2024 and they will already be enforced in a lot of countries. I know that some countries are pushing uh well they've argued that the effective date should be pushed maybe to 2024 2025 is is that likely or do you think that this is going to be happening in the near future. Well for the income inclusion rule it seems less likely because more a lot of countries will introduce it from 2024 onwards more likely for the utpr probably what we will see anyhow the rules were supposed to come in from 2025 but now after seeing this letter from the US uh Republican committee that's a question mark. I don't know how many countries will seriously introduce utpr in the national law because that also means uh somehow taxing the U.S.

companies based on the pillar 2 calculations, assuming there's U.S. entities are undertaxed in nature, or they are below the 15 trait. Uh, according to the pillar 2 calculations, but I don't know in reality how many countries would want to tax U.S. companies through the UTBR. Uh, I don't know how many countries would like to risk a trade war with the US. So, uh, I for the UTBR, it's still difficult to tell when they will be, when it will be introduced, but within the EU directive, they've committed for first of, um, for 2025. So let's time will tell. So no, you know, I cannot give you a precise answer to this question, to be honest. So, Vikram, another high-level question, um, we're talking about potential trade wars, we're talking about complexity, we're talking about rules that, you know, are kind of put out by the court or able to handle the court. Who benefits from all of this? I think a lot of governments are just are going to collect money on this, um, project, but at the same time, what are

they going to do with the money. They will just give it back to the taxpayers, or they will in one way or another, at least the countries which were friendly towards the taxpayers. Probably countries which are not in which you see that, you know, the relationship between taxpayers, the Chinese wall between um or let's say let me not call it a Chinese well. There's a wall between taxpayers and tax administrations. Um, uh, probably in those countries, uh, the tax administrations will be happy to get, uh, some extra revenues, but a lot of tax-friendly jurisdictions, um, countries you would see, you know, governments coming up with schemes trying to give it back to the taxpayers in one way or than others. So this becomes a bit circular in nature in my humble view. So again, to go back to the treaty discussion in an issue that's always near and dear to my heart, kind of competent Authority and dispute resolution, what does that do for the current framework? I know there's some kind of discussions about what could potentially come into, but how does this impact the

current component Authority framework. If we've had some discussions that hey, this may violate a treaty, or that we think this definitely violates a treaty, how does that framework come into play here with pillar 2? Is this something you think they just won't touch, or is it going to be kind of on the table of competent authorities to have these discussions around some of these rules? Well, actually, when you um think about pillar two rules, well, pillar two rules, they are domestic law rules. Now, domestic law rules, which will be implemented in domestic tax law, of course, at the same time, countries have tax treaties with each other. The question is, can any pillar two issues be resolved within the existing tax treaties? But if you look into mutual agreement procedure article, it says article 25, 1 on the OECD model of the U.S. practice, U.S. treaty networks, you would say that, well, 25, 1 only resolves treaty-related issues. So when you have a, you know, withholding tax issue, we have domestic withholding tax is 35, the treaty says 10.

or whether there's an interpretation issue with respect to the LOB clause, or the saving clause, or the permanent establishment definition. All these issues are trans surprising. All these issues are caught within the scope of tax treaties. But this pillar two stuff are domestic law issues. So if one country disagrees with the top of tax calculations made by another country, I don't think this can be solved under Article 25, which deals with the mutual agreement procedures. Is it 25 in the U.S. model also? Um, okay. So it cannot be solved because these are not treaty-related issues. These are all domestic law issues. So you know all these pillar 2 issues on top of tax calculations, they are outside the treaty Network. So what is being proposed right now, um, by the OECD, and they released the tax certainty document. And in the tax certainty or document, they spoke about dispute prevention for globe rules and dispute resolution for globe rules. On the dispute prevention side, they're reinforced and the ICAP project. The US is a part of this ICAP project.

essentially, they basically said, well, two kinds of eye-caps can be designed. One is, but you know, you can integrate the global rules in the existing icap process. Or whether you come up with an independent Globe pillar 2 icap process for dispute prevention. Well, that would be a welcome development, but the practical reality is that developing countries are not surely a part of this icap project. So, you just have a bunch of developed countries and the US, uh, as well as some, some other, let's say, it's the developed countries who are mostly, who mostly participate in this icap. Developing countries, at least some, some, some, some, or to be honest, some Tax Administration I spoke to about icap, they don't even know what icap is. So, they don't even know what that is. So, on the dispute prevention side, sticking that to the rest of the world would, I think, it would be challenging. But at the same time, you can develop some nice ideas. You can leverage on the existing icap mechanism and develop a certain model for dispute prevention.

which is welcome for taxpayers anything at this stage is welcome for the taxpayers because this is going to become uh um this is going to be so there's going to be so many problems with these rules so much litigation around these rules um somehow it seems to be undermined at this stage but when I read the rules and you know when I'm teaching these rules to taxpayers tax administrations or even my students they themselves say this is like the crazy amount of disputes can arise under these rules so that was in the dispute prevention side then on the dispute resolution side there well there are two options that are being contemplated uh more seriously one is the one is to open up a multilateral convention because the nature of disputes here could be bilateral or multilateral in nature um or pure domestic dispute resolution mechanism um well both options are uh being currently discussed at the level of the oecd but the recent document that was released for in uh in the public the recent documents which were released in

the public comments indicate that uh the most favored route is the multilateral convention. By taxpayers and by large associations, they favor this route. Uh, but if this route is not possible because many countries may not sign up to a multilateral convention, then probably they'll have to go for the domestic dispute resolution mechanism, which could actually also be fine for the taxpayers. Um, you know, they get something. Maybe it's not the most. It's not the best thing, but something is better than nothing at this stage. Going back to the article 25 discussion, I know I think you're right on article on 25 1. And then 25 3. It's it's typically reserved to to the company authorities. What about 25-2 in taxation not in accordance with the treaty? Could someone try to squeeze this in there or is that still? Yeah. So to 25 1 and 25 too they go hand in hand and basically they talk about uh, you know, just becoming a 3D interpretation issue. So in a paper that

we had written long time ago. We basically said that all 3D conflicts, like for example, a compatibility of utpr with tax treaties, that can really be challenged under article 25(1) um, because that's a 3D issue. We are talking about compatibility of utpr with article 9 of tax treaties, article 7 of tax treaties, or article 10(5) which deals with taxation of undistributed profits, or basically it says you cannot tax undistributed profits of companies. Um, that well, this you can actually challenge all your iir utpr rules and uh, this route, and basically you say there's a conflict with 3D provisions, then you go in for map and then possibly for arbitration, um, that is that can be done but pure Globe top of tax calculation disputes that seems to be outside the scope of tax release, yeah, so it's about how you kind of slice the issue you put in front of the company authority to an extent, yeah, so for example, if tomorrow Korea introduces

the UTPR and the start taxing U.S. multinationals. The first thing you, I guess you guys can do, is you can start the article 25 map and say this is a treaty or ride because 3D override issues can be brought within article 25, and then you say, well, if the Koreans, they don't accept the map, then possibly then you can go for arbitration. I guess before we wrap it up, thanks a ton for joining. One last question from my perspective, which is where do you think this goes in 12 months? Do we see UTPRs being enforced, or does everybody back down and rely on a combination of QDM, TT, and IIR? Yes, um, well, basically what we will see in the future is the rise of QDM TTS, to be honest. I mean, this is what a lot of countries will do, and then on the tax competition side, they will have the QRTCs. They will try to see how can we build up things, how can we remodel our existing incentives or come up new.

incentive ideas and stick it within this umbrella of QRTCs. The QRTC provision itself, they may just go, they may go under, they may undergo a substantial change. That's not what the OECD is currently working on. They are busy with the technical issues right now, but this is something for the future where they will try to police tax incentives. So, this is pure policing of tax incentives. So, QDM-TTS and QRTC seems to the future, possibly the IIR-UTPR. I'm really skeptical about actual countries actually trying to collect top-up taxes through the UTPR. I think the UTPR was honestly squeezed into scare countries to adopt IRS and QDM-TTS. But if some country tries to enact a UTPR and actually tries to collect taxes through a UTPR, I'm sure that taxpayers will start challenging this before code, saying this is treaty overrides. For me, it's obvious. It is a treaty override. And the chances of you winning or you representing taxpayers and the

taxpayers winning seems quite high for me when it comes to a utpr challenge. Less probably with a iiant challenge, it's still possible, unless possibly, uh, but on the utpr, it's just obvious for me. Yeah, you heard it here again, utpr, mutually assured destruction, never designed to work well. Vikram, thank you again so much for joining. This has been a great conversation. I had a lot of fun, and hopefully we can have you back to talk about some of these things as they develop. But so so much for the time, we really appreciate it. Well, actually, yes, we should definitely do another one on trans-surprising and filler two rules, because we were supposed to speak about that today, but she had to speak about other things. That's fine. [Laughter] Yeah, stay tuned, exactly. Thanks all, once again. Thank you all. Yeah, thank you for joining us for today's episode of Guilty Conscience. If you like what you're hearing, be sure to subscribe in your favorite podcast app so you don't miss any future conversations. Skadden's tax team is recognized.

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Update on Pillar Two: Where it Stands Today and What To Expect

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Update on Pillar Two: Where it Stands Today and What To Expect

Update on Pillar Two: Where it Stands Today and What To Expect

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