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 Tax Certainty Consultation
On February 3, 2023, TEI provided comments to the Organisation for Economic Co-operation and Development ("OECD") regarding its public consultation on GloBE tax certainty under the OECD's two pillar approach to the tax consequences of the digitalization of the economy. The Institute's comments focused on preventing and resolving tax disputes arising from the GloBE rules. TEI recommended the OECD certify that jurisdictional laws implementing the GloBE rules are consistent with those rules, required jurisdictions adopting the GloBE rules commit to dispute resolution, among other things.
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.