Keynote: Manuel de los Santos Poveda, Advisor, OECD
Moderators: Axel Nientimp, Partner, WTS (WTS Global - Germany) | Johan Visser, Director, Atlas (WTS Global - The Netherlands) | Sam Sim, Head TP Asia Pacific, WTS Global (WTS Global -Singapore) | Gorka Echevarría, Global VAT Leader, Lexmark | Christian Kaeser, Global Head of Tax, Siemens | Raquel Saraiva, Global Head of Direct Tax, Maersk
Rules of global taxation are changing fast. The OECD is trying to develop a consensus solution to the tax challenges arising from the digitalisation of the Economy, BEPS 2.0.
In Pillar 1 new proposals for a reallocation of taxing rights are discussed. The existing profit allocation and rules creating a taxable nexus are reviewed here. These developments are intended to reallocate more taxing rights to the source jurisdiction to overcome a feeling of unfairness of the current taxation of a few multinational enterprises and/or find a tax solution for the factual and technical aspects of these new business models.
This panel discussion addresses the following topics: New allocation and nexus rules from a direct tax perspective and their implications on taxpayers are examined. Moreover, possible effects from an indirect tax perspective are considered if new allocation rules, especially the modified profit split and fractional apportionment, will disconnect the profit allocation somewhat from the underlying transactions. In addition, the reactions of countries, e.g. special taxes for data-driven business models and withholding taxes, are discussed. We will get an idea how direct and indirect tax specialists handle the high uncertainty regarding the new rules and what effect this development could have on the organisation of the tax department.
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