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Cross-border Tax Talks
May 24, 2023
Freshly Served: Germany’s latest Pillar Two Draft
Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?
Timestamps:
- 1:20 - A few months back, both Doug and Arne had the opportunity to separately interview Pascal Saint-Amans for their podcasts. What was Arne’s takeaway from the interview?
- 5:50 - What is the legislative process in Germany? When do we anticipate the Pillar Two rules will be finalized, and when will they be enacted for financial statement purposes?
- 9:45 - How will the expected OECD administrative guidance be incorporated into German law?
- 12:00 - Is it fair to say that under German constitutional law the legislation could refer to the OECD guidance?
- 14:20 - Do we have implementation dates for Germany’s GloBE rules?
- 16:30 - There were a lot of details about compliance in the German Pillar Two draft legislation. What is the summary?
- 21:25 - How does Arne see the GloBE Information Return playing out in Germany?
- 22:55 - The EU directive was not prescriptive with regards to the QDMTT. How was that addressed in Germany?
- 25:15 - What about the deviations from the Model Rules, for example - the allocation of the CFC regime?
- 30:00 - There was no definition of an acceptable income inclusion rule (IIR) in the German rules. Is there any hope for the US GILTI regime?
- 32:40 - What is the general premise of Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?” Practically speaking, does Arne see the initial phase relief going anywhere?
Speakers
International Tax Services Global Leader, PwC US
Dr. Arne Schnitger
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