Doug McHoney (PwC's US International Tax Services Leader) finally convinces Calum Dewar (PwC's US Integrated Global Structuring Leader) to join him in the DC studio. They discuss what is commonly referred to as 'BEPS 2.0', but not before covering background and current status of what perhaps should now be called 'BEPS 1.0'. Doug and Calum address the unilateral responses to BEPS 1.0, as well how the EU and rest of the world have responded. They recognize that much is yet to be accomplished for BEPS 1.0, and conclude that a worthy discussion about a failure to meet implementation deadlines is well beyond the scope of this podcast!
Next Doug and Calum consider the evolution of BEPS 2.0, and how it's gone well beyond addressing taxation of the digital economy. They discuss how the permanent establishment tax concept is trying to catch up to modern business practices. Calum notes the difficulty in determining consensus around taxable presence and profit allocations. Then both spend time on Pillars 1 and 2, including the different approaches under each, how they might be implemented, and predictions for advancing. Of course, no Cross-border Tax Talks podcast would be complete without tying the conversation back to US tax reform, which they do (GILTI) without havering on.