This document provides an overview and introduction to a webinar on navigating the OECD's taxing of the digital economy initiative with Pillar I modeling. It outlines the agenda and speakers for the webinar. Technical instructions are provided for participating in the webinar. An update is then given on recent developments in the OECD's Pillar I negotiations, including statements from various countries and the timeline for reaching an agreement. Key aspects of the proposed new nexus and profit allocation rules under Pillar I are summarized. Finally, an overview is provided of the Pillar I modeling tool that will be demonstrated during the webinar.
The OECD's new work program would fundamentally change the way multinationals are taxed in the digital age, raising numerous questions of economic effects, compliance costs, and coordination between countries.
The four elements necessary for the OECD to be successful:
1.Identification of the scope and magnitude of the issues being addressed and how they are left unresolved by previous BEPS efforts.
2.A clear set of recommendations on both taxing rights and anti-base erosion policies that do the least amount of harm to economic growth.
3.Economic assessment of the potential impact of the policies on cross-border investment, cost of capital, foreign direct investment, compliance and administration costs, and countries’ tax revenue.
4.Commitment from countries to remove policies that conflict with the recommendations
Over the years, tax competition has led some countries to adopt more neutral, pro-growth business tax policies. This project could directly undermine that progress.
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Website: http://oe.cd/taxtalks
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join experts from the Centre for Tax Policy and Administration for a live webcast. Topics will include:
- Taxation of the digitalised economy.
- BEPS – including progress on the Multilateral Instrument and the latest on mutual agreement procedures.
- Tax policy – update on revenue statistics
- Tax certainty and the latest on the International Compliance Assurance Programme.
- Public discussion draft on mandatory disclosure rules.
On 9 October 02019, the OECD Secretariat published a proposal to advance international negotiations to ensure large and highly profitable Multinational Enterprises, including digital companies, pay tax wherever they have significant consumer-facing activities and generate their profits. This presentation gives a breakdown of the Secretariat Proposal for a "Unified Approach" under Pillar One.
For more information: http://oe.cd/taxtalks
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
With a number of recent and upcoming developments in the OECD's international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Topics covered:
- Package agreed by the G20/OECD Inclusive Framework on BEPS (IF)
- Next steps
The OECD's new work program would fundamentally change the way multinationals are taxed in the digital age, raising numerous questions of economic effects, compliance costs, and coordination between countries.
The four elements necessary for the OECD to be successful:
1.Identification of the scope and magnitude of the issues being addressed and how they are left unresolved by previous BEPS efforts.
2.A clear set of recommendations on both taxing rights and anti-base erosion policies that do the least amount of harm to economic growth.
3.Economic assessment of the potential impact of the policies on cross-border investment, cost of capital, foreign direct investment, compliance and administration costs, and countries’ tax revenue.
4.Commitment from countries to remove policies that conflict with the recommendations
Over the years, tax competition has led some countries to adopt more neutral, pro-growth business tax policies. This project could directly undermine that progress.
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Website: http://oe.cd/taxtalks
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join experts from the Centre for Tax Policy and Administration for a live webcast. Topics will include:
- Taxation of the digitalised economy.
- BEPS – including progress on the Multilateral Instrument and the latest on mutual agreement procedures.
- Tax policy – update on revenue statistics
- Tax certainty and the latest on the International Compliance Assurance Programme.
- Public discussion draft on mandatory disclosure rules.
On 9 October 02019, the OECD Secretariat published a proposal to advance international negotiations to ensure large and highly profitable Multinational Enterprises, including digital companies, pay tax wherever they have significant consumer-facing activities and generate their profits. This presentation gives a breakdown of the Secretariat Proposal for a "Unified Approach" under Pillar One.
For more information: http://oe.cd/taxtalks
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
With a number of recent and upcoming developments in the OECD's international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Topics covered:
- Package agreed by the G20/OECD Inclusive Framework on BEPS (IF)
- Next steps
With a number of important recent and upcoming developments in the OECD's international tax work, we invite you to join the OECD's Centre for Tax Policy and Administration (CTPA) for the latest tax update.
More information: http://oe.cd/taxtalks
Session by Raffaele Russo, Head, BEPS Project, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
► Digital economy is raising complex issues for VAT systems
► OECD (November 2015): “International VAT/GST Guidelines” published with a heavy
focus on the place of supply of cross-border supplies of services and intangibles and the
application of the principles of destination and neutrality
► Trend toward digital supplies becoming taxable in the country of consumption
► Businesses increasingly needing to make VAT decisions in real time (at the point
of sale)
► Policymaking is developing – typical developments:
► Joint and several liability for online marketplaces
► Active searches for non-established ESS suppliers
► Removal of low value import thresholds
► Tax authorities are going digital
► Plus increasing inter-governmental cooperation
► Reputational risk rising
As the COVID-19 crisis continues to affect people's lives and force governments to take action, the international tax agenda remains highly relevant. Work has continued throughout the crisis on the pressing issue of reaching a multilateral, consensus-based solution to the tax challenges arising from the digitalisation of the economy, and in other areas of the OECD's tax agenda. With a number of recent and upcoming developments in the OECD's international tax agenda, experts from the OECD Centre for Tax Policy and Administration gave an update on our work.
Topics included:
- Update on G20
- Tax and digitalisation update on Pillar One and Pillar Two
- Tax policy
- COVID-19 response – tax treaties and transfer pricing
- BEPS implementation and tax transparency
- Tax and crime
Visit our website: http://oe.cd/taxtalks
HDG - Base Erosion & Profit Shifting (BEPS) - Conceptual Analysis & Country b...Hitesh Gajaria
How Tax Authorities are Globally Coming Together to Combat the Digital Disruption
World's Largest Cab Co ... Owns No Cabs! - (Uber)
Largest Accommodation Provider .... Owns No Real Estate! (Airbnb)
World's Most Valuable Retailer .. Has No Inventory!
World's Largest Movie House ... Owns No Cinemas! (NetFlix)
Most Popular Media Owner .. Creates No Content! (Facebook)
Join senior members from the OECD's Centre for Tax Policy and Administration (CTPA) for a webcast as they give the latest update on the OECD/G20 BEPS Project.
View the webcast: http://www.oecd.org/ctp/beps-webcast-update-on-2014-deliverables.htm
Digitalisation has a wide range of implications for taxation, impacting tax policy and tax administration at both the domestic and international level. As a result, the tax policy implications of digitalisation have been at the centre of the recent global debate over whether or not international tax rules continue to be fit for purpose in an increasingly changing environment.
Presentation from the International Taxation session at the ICTD 7th annual meeting. The panel featured a discussion with Sol Picciotto, Alex Ezenagu, Michael Durst, Catherine Ngina Mutava, Martin Hearson, and Annet Oguttu.
With a number of recent and upcoming developments in the OECD's international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy, in view of the upcoming G20 Finance Ministers meeting.
Website: http://oe.cd/taxtalks
The digitalization of the global economy has amplified the problem of tax avoidance and tax fairness and led to a rise in digital taxes around the world. This webinar seeks to discuss ways for East Africa to address two crucial issues:
Linking taxation rights to where value is created
Reforming the current corporate income tax system to disincentivize transfer pricing to the jurisdiction with the lowest tax rate.
This presentation by Gioia de Melo (OECD Centre for Tax Policy and Administration) was delivered during the launch of the OECD Investment Policy Review of Uruguay on 12 July 2021.
Find out more at: https://www.oecd.org/investment/oecd-investment-policy-reviews-uruguay-1135f88e-en.htm
With a number of important recent and upcoming developments in the OECD's international tax work, we invite you to join the OECD's Centre for Tax Policy and Administration (CTPA) for the latest tax update. Topics include:
1. G20
2. Inclusive Framework on BEPS, including the Multilateral Instrument
3. Tax transparency
4. Tax certainty
5. VAT/GST
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
With a number of important recent and upcoming developments in the OECD's international tax work, we invite you to join the OECD's Centre for Tax Policy and Administration (CTPA) for the latest tax update.
More information: http://oe.cd/taxtalks
Session by Raffaele Russo, Head, BEPS Project, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
► Digital economy is raising complex issues for VAT systems
► OECD (November 2015): “International VAT/GST Guidelines” published with a heavy
focus on the place of supply of cross-border supplies of services and intangibles and the
application of the principles of destination and neutrality
► Trend toward digital supplies becoming taxable in the country of consumption
► Businesses increasingly needing to make VAT decisions in real time (at the point
of sale)
► Policymaking is developing – typical developments:
► Joint and several liability for online marketplaces
► Active searches for non-established ESS suppliers
► Removal of low value import thresholds
► Tax authorities are going digital
► Plus increasing inter-governmental cooperation
► Reputational risk rising
As the COVID-19 crisis continues to affect people's lives and force governments to take action, the international tax agenda remains highly relevant. Work has continued throughout the crisis on the pressing issue of reaching a multilateral, consensus-based solution to the tax challenges arising from the digitalisation of the economy, and in other areas of the OECD's tax agenda. With a number of recent and upcoming developments in the OECD's international tax agenda, experts from the OECD Centre for Tax Policy and Administration gave an update on our work.
Topics included:
- Update on G20
- Tax and digitalisation update on Pillar One and Pillar Two
- Tax policy
- COVID-19 response – tax treaties and transfer pricing
- BEPS implementation and tax transparency
- Tax and crime
Visit our website: http://oe.cd/taxtalks
HDG - Base Erosion & Profit Shifting (BEPS) - Conceptual Analysis & Country b...Hitesh Gajaria
How Tax Authorities are Globally Coming Together to Combat the Digital Disruption
World's Largest Cab Co ... Owns No Cabs! - (Uber)
Largest Accommodation Provider .... Owns No Real Estate! (Airbnb)
World's Most Valuable Retailer .. Has No Inventory!
World's Largest Movie House ... Owns No Cinemas! (NetFlix)
Most Popular Media Owner .. Creates No Content! (Facebook)
Join senior members from the OECD's Centre for Tax Policy and Administration (CTPA) for a webcast as they give the latest update on the OECD/G20 BEPS Project.
View the webcast: http://www.oecd.org/ctp/beps-webcast-update-on-2014-deliverables.htm
Digitalisation has a wide range of implications for taxation, impacting tax policy and tax administration at both the domestic and international level. As a result, the tax policy implications of digitalisation have been at the centre of the recent global debate over whether or not international tax rules continue to be fit for purpose in an increasingly changing environment.
Presentation from the International Taxation session at the ICTD 7th annual meeting. The panel featured a discussion with Sol Picciotto, Alex Ezenagu, Michael Durst, Catherine Ngina Mutava, Martin Hearson, and Annet Oguttu.
With a number of recent and upcoming developments in the OECD's international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy, in view of the upcoming G20 Finance Ministers meeting.
Website: http://oe.cd/taxtalks
The digitalization of the global economy has amplified the problem of tax avoidance and tax fairness and led to a rise in digital taxes around the world. This webinar seeks to discuss ways for East Africa to address two crucial issues:
Linking taxation rights to where value is created
Reforming the current corporate income tax system to disincentivize transfer pricing to the jurisdiction with the lowest tax rate.
This presentation by Gioia de Melo (OECD Centre for Tax Policy and Administration) was delivered during the launch of the OECD Investment Policy Review of Uruguay on 12 July 2021.
Find out more at: https://www.oecd.org/investment/oecd-investment-policy-reviews-uruguay-1135f88e-en.htm
With a number of important recent and upcoming developments in the OECD's international tax work, we invite you to join the OECD's Centre for Tax Policy and Administration (CTPA) for the latest tax update. Topics include:
1. G20
2. Inclusive Framework on BEPS, including the Multilateral Instrument
3. Tax transparency
4. Tax certainty
5. VAT/GST
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
BYD SWOT Analysis and In-Depth Insights 2024.pptxmikemetalprod
Indepth analysis of the BYD 2024
BYD (Build Your Dreams) is a Chinese automaker and battery manufacturer that has snowballed over the past two decades to become a significant player in electric vehicles and global clean energy technology.
This SWOT analysis examines BYD's strengths, weaknesses, opportunities, and threats as it competes in the fast-changing automotive and energy storage industries.
Founded in 1995 and headquartered in Shenzhen, BYD started as a battery company before expanding into automobiles in the early 2000s.
Initially manufacturing gasoline-powered vehicles, BYD focused on plug-in hybrid and fully electric vehicles, leveraging its expertise in battery technology.
Today, BYD is the world’s largest electric vehicle manufacturer, delivering over 1.2 million electric cars globally. The company also produces electric buses, trucks, forklifts, and rail transit.
On the energy side, BYD is a major supplier of rechargeable batteries for cell phones, laptops, electric vehicles, and energy storage systems.
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
The Evolution of Non-Banking Financial Companies (NBFCs) in India: Challenges...beulahfernandes8
Role in Financial System
NBFCs are critical in bridging the financial inclusion gap.
They provide specialized financial services that cater to segments often neglected by traditional banks.
Economic Impact
NBFCs contribute significantly to India's GDP.
They support sectors like micro, small, and medium enterprises (MSMEs), housing finance, and personal loans.
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
where can I find a legit pi merchant onlineDOT TECH
Yes. This is very easy what you need is a recommendation from someone who has successfully traded pi coins before with a merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi network coins and resell them to Investors looking forward to hold thousands of pi coins before the open mainnet.
I will leave the telegram contact of my personal pi merchant to trade with
@Pi_vendor_247
Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
how to sell pi coins at high rate quickly.DOT TECH
Where can I sell my pi coins at a high rate.
Pi is not launched yet on any exchange. But one can easily sell his or her pi coins to investors who want to hold pi till mainnet launch.
This means crypto whales want to hold pi. And you can get a good rate for selling pi to them. I will leave the telegram contact of my personal pi vendor below.
A vendor is someone who buys from a miner and resell it to a holder or crypto whale.
Here is the telegram contact of my vendor:
@Pi_vendor_247
3. 3
Introduction to Zoom
How can you interact? Webinar support
Eleonora Zelger
Zoom Master
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assistance with Zoom, please write to Eleonora Zelger
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4. 4
Partner, Transfer Pricing
at Deloitte Switzerland
M A R T I N K R I V I N S K A S
Managing Director, Tax
at Deloitte US
B O B S T A C K
Manager, Transfer Pricing
at Deloitte Switzerland
A R J A N O O S T E R H E E R T
Director, Transfer Pricing
at Deloitte Switzerland
J E F F S M O L E R O F F
Managing Director,
International Tax at
Deloitte US
R Y A N D U C H E N E
With you today
6. 6
2015-2020
Work to date
2018 OECD interim report - March 2018
OECD policy note - January 2019
- Sets out the two pillar approach
Public consultation document - February 2019
- Comments sought on policy issues and technical aspects
- Followed by public consultation meeting - March 2019
Programme of work - May 2019
- Roadmap towards agreeing consensus solution by the end of 2020
Pillar One Secretariat proposal – Oct. 9, 2019
- Unified approach to nexus, profit allocation rule
- Public consultation
Pillar Two consultation document – Nov. 6, 2019
- Global Anti-Base Erosion Proposal
- Public consultation
Inclusive Framework statement – Jan. 31, 2020
- Reaffirms commitment to reaching consensus solution
- Outline of a unified approach to Pillar One
8. 8
Position Swiss government
• Switzerland has said there would be no “digital tax”, decided by the National Council’s Economic Commission
(June 23)
• The Commission feels that by introducing a national "digital tax", Switzerland would reverse its previous position.
• The Commission’s preference is not to shift away from taxation of profits to taxation of turnover - and if a shift is
required, to do so only within the framework of an international agreement rather than via national solo efforts.
• Feeling that such efforts would create chaos.
Decision of Swiss national council commission
9. 9
Digital services taxes on the march
Austria France
India Italy
Turkey UK
Uruguay Zimbabwe
Tunisia
Czech Republic Spain
Canada Indonesia
Poland New Zealand
Norway Slovenia
10. 10
Position US government
• The office of the United States Trade Representative announced on June 2, 2020 trade investigations into nine
countries’ plus the EU’s proposed or enacted “digital services taxes” (DSTs).
• The countries/jurisdictions being investigated are:
• Austria
• Brazil
• the Czech Republic
• the European Union
• India
• Indonesia
• Italy
• Spain
• Turkey
• the United Kingdom
• The investigations could lead to the imposition of tariffs on those countries’ exports to the US.
USTR Announcement – Investigation under 1974 Trade Act
11. 11
Position US government
• On June 17, 2020 U.S. Treasury Secretary Mnuchin sent a letter to four European finance ministers (France,
Italy, Spain and UK) claiming that discussions with respect to a new global tax framework occurring at the
OECD’s Inclusive Framework had reached an “impasse.”
• The U.S. remains opposed to measures that focus solely on digital businesses.
• In light of COVID-19 and the health and economic challenges it poses, the U.S. does not believe 2020 is a
suitable time to be conducting such negotiations.
• The Secretary calls upon the OECD to “pause discussions of Pillar 1, with a view towards resuming later this
year.”
• The letter threatens “appropriate commensurate measures” if countries choose to go forward with DSTs.
• In response, the finance ministers of the U.K., Italy, France and Spain urged moving forward on a phased basis,
starting with automated digital services.
• Furthermore, the OECD Secretary-General now recommends that all members of the Inclusive Framework on
BEPS remain engaged in negotiations, with the goal of reaching a multilateral solution by the end of 2020.
Secretary Mnuchin Letter of June 17, 2020 to Finance Ministers of the U.K., Italy, Spain and France
12. 12
Pillar 1: Recap of new nexus and
profit allocation rules
Unified approach
13. 13
Profit allocation
Pillar One: Three-tier mechanism
New taxing right—beyond the arm’s-length principle
Allocates a portion of deemed residual profit to market
jurisdictions using a formulaic approach
Amount
A
Fixed “baseline” return for marketing and distribution functions,
based on the arm’s length principle
Amount
B
Additional return beyond Amount B based on transfer pricing
analysis and subject to robust dispute resolution processes
Amount
C
14. 14
Scope
Amount A: New taxing right
Two broad groups of business have been identified as in scope, which:
• Can participate in a “sustained and significant manner” in the economic life of a
market country,
• With or without local physical operations
Automated digital services Consumer-facing businesses
Activities may need to be segmented to separate in-scope from out-of-scope segments.
15. 15
Thresholds
Amount A: New taxing right
De minimis test on the total aggregated group in-scope
revenue from consumer-facing activities and/or automated
digital services
A carve-out where the total profit to be allocated under
Amount A does not meet a de minimis amount
Group gross revenue threshold
Possibly in line with the €750 million revenue threshold
used for country-by-country reporting
A number of thresholds are being considered but are not yet agreed:
16. 16
New profit allocation rules
Amount A: New taxing right
Determine the total before-tax profit
or loss of the group
Exclude “deemed” routine profit to
calculate a deemed residual or
excess profit
Treat a total percentage of deemed
residual profit as attributable to
market jurisdictions
Allocate profits between eligible
market jurisdictions using allocation key
• Use consolidated group financial statements
• Consideration is being given to the use of business
line and/or regional segmentation
• Fixed percentages
• Possible variation by market jurisdiction size and
industry
• A “rough justice” approach
• Based on sales generating nexus
• Possible variation by business model
1
2
3
4