Cross-border Tax Talks
December 15, 2022
UK Updates: Pillar Two is Coming
Doug McHoney, PwC’s International Tax Services Global Leader, is in Barcelona, Spain at PwC’s Global Tax Symposium. On this episode, Doug is joined by Matt Ryan, a UK-based International Tax Partner with PwC. Doug and Matt discuss the UK’s parliamentary process, Liz Truss’s resignation, the corporate tax proposed changes, and Pillar Two, including a qualified domestic minimum tax, the income inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.
Timestamps:
- 1:00 - For those baffled by the UK’s parliamentary process, how is a Prime Minister elected?
- 5:30 - The new Prime Minister and Chancellor of Exchequer recently proposed significant changes to UK corporate taxation. What are those proposed changes?
- 8:00 - Where does the UK currently stand with enacting Pillar Two?
- 11:30 - Do you expect the UK to be the first country to move forward with enacting Pillar Two?
- 13:30 - How does the UK consultation process work when finalizing legislation?
- 17:50 - There are a lot of questions and uncertainties surrounding the implementation framework of Pillar Two. Let’s touch on a few of those:
- 18:00 - Asset transfers, particularly regarding consolidated groups
- 21:40 - Deferred taxes, particularly local accounts and consolidated accounts
- 24:00 - Year-end adjustments
- 28:50 - What has been the biggest hurdle or challenge for clients as they assess the impact of Pillar Two? Is it systems and data?
Speakers
International Tax Services Global Leader, PwC US
Matt Ryan
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