IBA Annual Conference Miami 2022

30 Oct - 4 Nov 2022

Room 208, Level 2

Session information

Pillar II; OECD, EU, state aid?

Tuesday 1 November (0930 - 1045)

Room 208, Level 2
View location
Conference area
Networking hub (Exhibition hall)
Meeting rooms
Session rooms
The full venue map is available on the delegate homepage


Taxes Committee (Lead)


The Two-Pillar Solution acknowledges the importance of the STTR in achieving a consensus on Pillar II for developing countries, but so far has only identified interest, royalties and a “defined set of other payments” as being subject to the rule, has set the minimum rate for the STTR at a range from 7.5% to 9% and has relegated implementation to a bilateral negotiation upon request. This panel will explore the practical tension inherent in the Pillar II proposals in addressing the concerns of developed and developing countries with a particular emphasis on the challenges faced by developing countries in protecting their tax base and competing for revenue.

Session / Workshop Chair(s)

Sandy Bhogal Gibson, Dunn & Crutcher, London, England
Rebecca Keß Flick Gocke Schaumburg Partnerschaft mbB, Frankfurt, Germany


Michael Orchowski Sullivan & Cromwell LLP, London, England
Clemens Schindler Schindler Rechtsanwälte GmbH, Vienna, Austria
Amit Singhania Shardul Amarchand Mangaldas & Co, New Delhi, Delhi, India
Jason Yen EY, Washington, District of Columbia, USA