IBA Annual Conference Miami 2022
30 Oct - 4 Nov 2022
Room 208, Level 2
Session information
Committee(s)
Taxes Committee
(Lead)
Description
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 |
Speakers
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 |