What Does Tax Certainty Mean in a BEPS 2.0 World?

KPMG LLP (KPMG) is pleased to invite you to a one-hour TaxWatch webcast replay that addresses the latest thinking on what “tax certainty” might look like in a BEPS 2.0 world.

BEPS 2.0 guidance is still evolving, but there is little doubt that what is being contemplated will have a lasting impact on the global taxation system, including how companies and tax authorities handle international tax disputes. The OECD/G20 Inclusive Framework (IF) statement on October 8, 2021 finalized a high-level agreement on a tax certainty framework for Amount A. The OECD plans to have a series of public consultations regarding Amount A in 2022. The time is right to consider what is on the table. 

This webcast includes:

• A focus on October statement’s tax certainty commitments: 
  • In-scope multinational enterprises (MNEs) will have access to mandatory and binding dispute prevention and resolution mechanisms that will cover Amount A.
  • In-scope MNEs will also benefit from mandatory and binding dispute prevention and resolution mechanisms that will cover related issues such as transfer pricing and permanent establishment disputes. 
• A discussion with Sonja Schiller, Head of Global Tax Controversy at Netflix, Inc., about how a framework to deliver on these commitments could be designed and how the process might play out from a practical perspective.
• Insights into how the Amount A certainty proposals may influence dispute prevention and resolution for taxpayers outside the scope of Amount A.