EMEA Direct Tax Committee

The European Direct Tax Committee covers income-based tax aspects of European operations, including tax treaty matters, and develops the Institute’s positions and submissions to taxing authorities in European countries, as well as the European Union and OECD.

TEI Comments on OECD Pillar Two GloBE Information Return Consultation

On February 3, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the GloBE Information Return under Pillar Two of the OECD's project on the digitalization of the economy. The Institute's comments primarily focused on the ways to reduce the volume of information required under the return, by both eliminating information that is reported via other means and reporting on a jurisdictional basis rather then entity-by-entity.

TEI Comments on OECD Pillar One Amount B Consultation

On January 25, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the OECD's public consultation on the design elements of Pillar One, Amount B. TEI's comments included the need to broaden the scope of Amount B to achieve its goal of transfer pricing simplification, ensure timely and binding dispute resolution procedures, and clarify the interaction between Amount B and the marketing and distribution safe harbor of Amount A. TEI's comments were prepared under the aegis of its EMEA Direct Tax Committee. Benjamin R.

TEI Files Comments on OECD Pillar One and Pillar Two Blueprints

On December 13, TEI submitted comments to the OECD regarding its BEPS Project Pillar One and Pillar Two Blueprints. TEI’s comments focused on the specific questions posed by the OECD in its consultation document, including issues related to Amounts A and B under Pillar One, as well as the GloBE under Pillar Two.

TEI Files Comments regarding 2020 OECD Review of CbC Reporting

On March 5, TEI submitted comments to the OECD regarding its public consultation document entitled Review of Country-by-Country Reporting (BEPS Action 13).

TEI Comments on the OECD’s “GloBE” Proposal

On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.

TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One

On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.

TEI Files Comments regarding the Platform for Collaboration on Tax’s Draft Transfer Pricing Toolkit

On November 7, TEI submitted comments to the Platform for Collaboration on Tax – a joint initiative of the World Bank, OECD, International Monetary Fund, and United Nations – regarding its draft transfer pricing documentation toolkit for developing countries.

TEI Submits Comments to the OECD regarding Digitalization of the Economy Consultation

On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.

TEI Submits Comments to the Australian Treasury regarding Digital Economy Discussion Paper

On November 29th, TEI submitted comments to the Australian Treasury regarding its Discussion Paper on the digital economy and Australia’s corporate tax system.

TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions

On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.