BEPS: Collection of KPMG Insights

December 22, 2022 | Pillar Two Implementation: U.S. Multinationals Impacts and Considerations

On December 16, the European Union achieved unanimity for an EU Directive for implementing BEPS Pillar Two. Other countries have also taken implementation steps. Companies that meet the Pillar Two threshold will be facing implementation issues that may affect cash taxes and effective tax rate and add compliance and administrative requirements. Watch this video to learn about implications and considerations for U.S. groups.

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December 21, 2022 | Pillar Two implementation package

This KPMG Report provides observations and analysis of the implementation package related to the Pillar Two global anti-base erosion (GloBE) rules, released by the OECD/G20 Inclusive Framework on BEPS on December 20, 2022.

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December 21, 2022 | Tax Transparency

In this episode of KPMG Harnessing the Power of ESG podcast, leaders from the KPMG Tax ESG practice discuss the role of tax transparency in a company’s overall ESG journey: what it means, what the standard setters are prescribing, what the legislators are mandating, and how companies are approaching it.

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October 5, 2022 | A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow?

The widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability This episode of KPMG Inside International Tax discusses the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions.

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September 26, 2022 | Future of the Arm's-Length Principle

In a series of three articles, which appeared in Tax Notes International, the authors assess the merits of the arm's-length principle and the significant problems with global formulary apportionment—the perceived alternative. They also consider the impact that the BEPS 2.0 project and other OECD initiatives may have on the future of transfer pricing.

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August 25, 2022 | Where Did Pillar One and Pillar Two Come From?

The impacts of Pillar One and Pillar Two on transfer pricing vary by jurisdiction, taxpayer, and the likelihood of ultimate adoption. This KPMG Exploring Transfer Pricing podcast provides a high-level overview of the two pillars, a starting point for understanding the possible implications for transfer pricing.

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July 11, 2022 | Amount B: The Forgotten Piece of the Pillar 1 Jigsaw

This article, which appeared in Tax Notes International, examines a significant but frequently overlooked piece of the OECD’s Pillar 1 proposal, Amount B. The KPMG authors explain how Amount B could work, discuss implementation challenges, and consider how businesses can prepare.

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July 4, 2022 | The Diverging Paths of Pillar 1 and 2

In this article, which appeared in Tax Notes International, the KPMG authors examine the status of the OECD’s two-pillar approach to modernizing the international tax system and consider the international implications of the different paths countries are taking to implement Pillars 1 and 2.

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June 22, 2022 | A Tough Pill(ar) to Swallow: Computing GloBE ETR for U.S. Multinationals

KPMG Inside International Tax Episode 07-2022 | This podcast episode examines the current status of Pillar Two implementation and the potential complexities that U.S. multinationals may have to navigate as the current U.S. tax rules interact with any future Pillar Two legislations implemented by our trading partners.

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May 13, 2022 | What's the Deal with Local Files and Local Documentation?

KPMG Exploring Transfer Pricing Episode 05-2022 | Is it Local? When it comes to country-specific transfer pricing reports, acclimate yourself to the local terminology, and don't get tripped up by the different titles and requirements.

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May 2022 | Pillar Two: Preparing for a Consensus-Less Future

The issue of KPMG Chief Tax Officer Insights explores how CTOs are approaching scenario planning for potential Pillar Two rules.

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April 18, 2022 | How Can You Master the File?

Exploring Transfer Pricing Episode 04-2022 | This podcast episode discusses the mastery of the Master File, aka, the “bass line” in the symphony of global transfer pricing documentation.

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March 18, 2022 | What Is Country-by-Country Reporting? (Part 2)

KPMG Exploring Transfer Pricing Episode 03-2022 | With the onset of public country-by-country reporting, coordination, transparency, and analysis is key. Listen to this podcast and learn about some of the risks and mitigation tools and practices associated with interpreting data.

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March 18, 2022 | Analysis of Pillar Two Model Rules for 15% Global Minimum Tax

KPMG report provides an analysis of Pillar Two model rules following release of commentary published by the OECD on March 14.

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March 15, 2022 | The GloBE Rules: Bye Bye American Pie

KPMG Inside International Tax Episode 04-2022 | Pillar 2 GloBE rules are discussed and explore how these rules could deny U.S. multinationals the benefit of Congressionally sanctioned tax incentives.

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February 18, 2022 | EU OK on CbC ESG: What Does That Spell for MNEs?

KPMG Destination Country X Episode 01-2022 | For several years, the European Union’s ambitious public country-by-country reporting agenda has been an on-again, off-again affair—and one arguably more “off” than “on.” But with Portugal driving the EU agenda, we finally have resolution. This podcast provides an update on this development and discusses the potential implications for multinational enterprises. [24:33]

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February 11, 2022 | What Is Country-by-Country Reporting? (Part 1)

KPMG Exploring Transfer Pricing, Podcast Episode 02-2022 | Step by step, country by country... Tax authorities and taxpayers get closer and closer in sync.

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February 6, 2022 | Public Consultation Document on Pillar One, Nexus and Revenue Sourcing Draft Model Rules

KPMG report examines the draft OECD February 4 model rules for nexus and revenue sourcing, the first building block of "Amount A."

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January 14, 2022 | Drivers of Change – BEPS 2.0: OECD Blueprints on Pillars One and Two

This KPMG retrofitting cross-border tax structures video provides insights on BEPS 2.0 developments, the potential impact on U.S.-based multinationals and common tax structures, what may be coming next in 2022, and how U.S. tax legislative developments may be affected.

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January 11, 2022 | Around the GloBE: Exploring the Pillar Two Model Rules

KPMG Inside International Tax podcast – In late December, the OECD released model rules for a 15% global minimum tax, a component of the two-pillar approach to taxing the digital economy. In this episode, we cover the latest guidance on Pillar Two’s income inclusion rule and undertaxed payments rule (“GloBE rules”), the interaction of Pillar One and Pillar Two timelines, and the implementation implications of U.S. legislative (in)action.

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January 7, 2022 | BEPS 2.0: Issues and Implications for Latin America | Tax Management International Journal

The article provides an overview of the Organization for Economic Cooperation and Development’s (OECD) Pillars 1 and 2, and describes some of the most immediate issues implicated by BEPS 2.0 in Latin America as identified by authors from Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Mexico, Panama, Peru, and Uruguay.

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