Between Two Pillars, Part 3: Mind the Gap

In April and July podcast episodes, we explored the OECD’s two-pillar approach to the challenges of taxation of the digital economy, including a historic July 1 Inclusive Framework agreement. In this episode, we return to BEPS 2.0 to unpack the most recent statement from the OECD’s Inclusive Framework, which fills in significant details left open in July but leaves unanswered many important issues, and to explore the remaining political and practical obstacles to final implementation of the two-pillar approach.

How significant is it that Ireland, Estonia, and Hungary have all joined the deal, and that Cyprus has not? What design details have been agreed to, and what remains to be done? How do countries translate their political commitments into implementation, how soon can we expect countries to enact these rules into their domestic law, and what role does U.S. tax reform play? What should multinational enterprises be doing in anticipation of BEPS 2.0?

Our host Gary Scanlon interviews Manal Corwin (formerly Treasury Department International Tax Counsel and Deputy Assistant Secretary of Tax Policy for International Affairs) and Marcus Heyland (formerly an adviser to the OECD on BEPS 2.0) to get their informed perspective on the breaking developments at the OECD and G20. 

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