Cross-border Tax Talks

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February 18, 2021

Grab your passport: global tax policy update

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Will Morris (PwC's Deputy Global Tax Policy Leader) discuss important updates to international tax policy. Doug and Will cover: recent updates to the OECD's base erosion and profit shifting (BEPS) project—BEPS 2.0—including the proposed timeline for agreement, unresolved issues in the Pillar One and Pillar Two Blueprints, and potential challenges to implementation; recent IRS and Treasury appointees and how these individuals may affect domestic and international policy; the challenges of amending US treaties even if the OECD's Inclusive Framework reaches consensus; the EU Court of Justice's recent decision in Lexel AB v. Skatteverket regarding the EU's 'freedom of establishment' concept and how this decision may cause challenges in implementing Pillar Two in the European Union; recent developments concerning digital service taxes (DST), including a look at the UK's proposed online sales tax and diverted profits tax, India's equalization levy, and Indonesia's electronic transactions tax; a recent court decision in France related to a permanent establishments; and how taxpayers can prepare for international tax disruption.


  • 02:54 - BEPS 2.0 update
  • 09:57 - Recent IRS and Treasury appointees
  • 16:30 - Challenges in amending US treaties­
  • 18:57 - EU's 'freedom of establishment' concept / EU Court of Justice update­
  • 22:49 - DSTs and the UK's proposed online sales tax and diverted profits tax­
  • 26:45 - India's equalization levy
  • 28:39 - Indonesia's electronic transactions tax­
  • 29:56 - Recent French case on permanent establishments­
  • 33:05 - Key takeaways for taxpayers

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Contact us

Doug McHoney

International Tax Services Co-Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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