until we see each other in person
at the Four Seasons in Washington, D.C.
June 27, 2022
8:30 a.m. – 6:00 p.m.
6:00 – 7:30 p.m. Cocktail Reception
June 28, 2022
8:00 a.m. – 1:00 p.m.
We’re back! Now in its 15th year, this annual conference provides a unique opportunity for the U.S. business community to interact with key representatives from the OECD Centre for Tax Policy and Administration (“CTPA”) as well as key members of the OECD’s Committee on Fiscal Affairs: including Pascal Saint–Amans, Director, CTPA, and Grace Perez–Navarro, Deputy Director, CTPA. Speakers will also include Fabrizia Lapecorella, the new Chair of the OECD’s Committee on Fiscal Affairs and Director General for International Taxation at the Italian Ministry of Finance. The focus of the conference will be on the Two Pillar Solution to the Tax Challenges of the Digitalization of the Economy but will also cover other key international tax issues.
What You Need To Know
- Peter Robinson, President and CEO, USCIB
- Fabrizia Lapecorella, Chair, OECD Committee on Fiscal Affairs; Director General of Finance, Ministry of Finance, Italy
Two Pillar Solution to Tax Challenges of Digitalization of the Economy
After years of discussions, in October 2022, more than 130 countries and jurisdictions of the OECD/G20 Inclusive Framework on BEPS agreed a landmark Statement and Detailed Implementation Plan on the two-pillar approach to addressing the tax challenges arising from the digitalization of the economy,which was subsequently endorsed by G20 Finance Ministers and Central Bank Governors at their October meeting. Pillar One is intended to ensure a fairer distribution of profits and taxing rights among countries with respect to the largest MNEs through an innovative formulaic approach. Pillar Two sets a floor on tax competition on corporate income tax through the introduction of a global minimum corporate tax that does not eliminate tax competition, but does set multilaterally agreed limitations on it. This panel will provide the broad overview of the work and discuss next steps.
Pillar One: Part I
Pillar One is intended to restore stability to the international tax system by bringing it into the 21st century. This panel will explore the overall design of the Pillar and dive into some of the more detailed questions including scope, scope exclusions and the tax base.
Luncheon and Keynote Address
Pillar One: Part II
This panel will continue the discussion of Amount A focusing on some of the other important structural features including revenue sourcing, administration as well as elimination of double taxation and the marketing and distribution safe harbor. Tax certainty issues will be covered in Session IX.
Increased Global Mobility of Workers—What does it mean for tax policy?
Digitalisation has led to significant changes in labour markets, with teleworking having expanded dramatically as a result of the pandemic and with new types of jobs that can be done anywhere increasing. Physical presence is a key determinant of corporate income tax nexus and taxing rights such as PE creation and company residence. Physical presence also plays an important role in transfer pricing (e.g., income allocation, profit attribution if PE is created). At the same time, tax incentives to attract so-called “digital nomads” are being introduced. The OECD issued some interim guidance at the onset of the pandemic but is it time to take a deeper look at these issues? This panel will discuss the tax treaty, transfer pricing and other implications of this trend for businesses, individuals and tax policy and tax administration.
Tax and Climate Change
Countries have committed to ambitious emissions reduction targets in their and a growing number have committed to net-zero greenhouse gas emissions by 2050 while others are already moving in that direction. However, and in spite of significant progress made to date, near-term policy actions on climate remain insufficient to meet the Paris Agreement objectives, and the diversity of policy approaches risks limiting their combined impact as well as elevating the likelihood of negative spillovers. To ensure the effectiveness of combined efforts and to avoid adverse interactions with trade and development agendas, the OECD has proposed establishing an inclusive forum for greater multilateral dialogue, informed and facilitated by technical and objective analysis of carbon pricing and other climate mitigation measures, building on the OECD’s comparative data in Taxing Energy Use. This panel will discuss the latest developments in this area.
Pillar Two: Global Minimum Tax
This session will focus on the second pillar, which sets out the Global Anti-Base Erosion rules (GloBE) and the Subject to Tax Rule (STTR). The GloBE rules, which were published in December 2021 and complemented by Commentary released in March 2022, aim to address the continued risk of profit shifting to entities subject to no or very low taxation through the development of two inter-related rules: an income inclusion rule and an under-taxed payment rule. The panel will discuss the main elements of the GloBE rules, STTR as well as the plan for implementation.
Tax Certainty: Dispute Prevention/Dispute Resolution | Session 1
Under the Pillars: Dispute Prevention and Resolution
Enhancing tax certainty is a key element of the Two Pillar Solution to the tax challenges arising from digitalisation. The October Statement calls for MNES that are in-scope of Pillar One to benefit from dispute prevention and resolution mechanisms to avoid double taxation for Amount A, including all issues related to Amount A. Given the formulaic approach to allocating profits under Amount A, this will call for innovative, multilateral approaches to dispute prevention and resolution. Amount B, which calls for simplification and streamlining of the application of the arm’s length principle as it applies to in-country baseline marketing and distribution activities is also intended to enhance tax certainty by reducing disputes on some of the most common transfer pricing cases. The Inclusive Framework is also considering tax certainty in the context of Pillar Two, through measures to ensure consistency, coordination, simplicity and safe harbours, as indicated in the recent public consultation document on the Implementation Framework. This panel will discuss the challenges and opportunities in designing rules to prevent disputes and ensure timely resolution of disputes under each of the Pillars.
Tax Certainty: Dispute Prevention/Dispute Resolution | Session 2
Beyond the Pillars: Dispute Prevention and Resolution
The OECD Forum on Tax Administration continues to explore ways to increase tax certainty for taxpayers and tax administrations by making certainty available earlier, by making certainty processes more efficient, and by providing opportunities for certainty to be provided on a coordinated or multilateral basis. This panel will discuss the latest developments in the ICAP programme, as well as work on streamlining the APA process, the possibility of multilateral APAs and MAP, and the wider use of standardised benchmarking, as well as other recent initiatives.
- Rick Minor, Vice President & International Tax Counsel, USCIB
- Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration
- Pascal Saint-Amans – Director, Centre for Tax Policy and Administration, OECD
- Grace Perez-Navarro – Deputy Director, Centre for Tax Policy and Administration, OECD
- Peter Robinson – President and CEO, USCIB
- Fabrizia Lapecorella – Director General of Finance of the Italian Ministry of Economy and Finance and Chair of OECD Committee on Fiscal Affairs
- Martin Kreienbaum – Director General, International Taxation, Federal Ministry of Finance, Germany
- Itai Grinberg – Deputy Assistant Secretary (International Tax Affairs), U.S. Treasury
- Mike Williams – Director, Business and International Tax, HM Treasury, United Kingdom
- Gael Perraud – Co–Chair, OECD Task Force on the Digital Economy; Director of International Taxation and European Affairs, Ministry of Economy and Finance, France
- Achim Pross – Head of International Cooperation and Tax Administration Division, Centre for Tax Policy and Administration, OECD
- Alan McLean – Chairperson, Business at OECD Committee on Taxation and Fiscal Affairs and Executive Vice President, Tax and Controller, Shell International Limited
- Tim McDonald – Chairperson, USCIB Tax Committee and Senior Vice President, Finance & Accounting, Global Taxes, The Procter & Gamble Company
- Louise Weingrod – Vice Chairperson, USCIB Tax Committee and Vice President, Global Taxation, Johnson & Johnson
The registration rate is $1,495 for USCIB members and $1,795 for non–members.
Registrations are non-refundable. Cancellations are liable for the full conference fee. You may send a substitute in your place for no additional charge. Substitutions must be requested, in writing, no later than Friday, June 10.
- USB Flash Drives with Background Documents will be included in materials handed out to attendees. Electronic copies are available to registered participants upon request.
- Hard Copies of PowerPoint Presentations will not be distributed. Electronic copies will be sent via email to participants when they are finalized.
Location Details: The conference will be held at the Four Seasons Hotel located at 2800 Pennsylvania Avenue NW. The meeting portion of the conference will take place in the Corcoran Ballroom located on the Banquet level. The Luncheon on Monday, June 27 will take place in the Dumbarton Conservatory next door to the Corcoran Ballroom. The Reception, also on Monday, June 27, will take place in the Seasons Restaurant on the Lower Lobby Level.
Wireless Internet: Wireless internet is available for conference attendees in the meeting room. Please ask a member of the conference staff for the wireless password. Complimentary internet is also available to conference participants in your hotel room.
Parking: Discounted Valet Parking is available at the conference venue, The Four Seasons Hotel, for conference attendees. Please pick up a parking validation sticker at the registration table for each day of the conference.
Metro: The nearest metro station is the Foggy Bottom-GWU station. Both Blue and Orange lines stop at the Foggy Bottom Metro. The Hotel is approximately a four-block walk from the metro. (Map below)
A limited number of rooms have been blocked at the reduced rate of $435/night plus 14.95% tax at the conference venue, The Four Seasons Hotel, Washington, D.C.
Unbooked rooms (if any) will be released for general sale on June 6, 2022, and the group rate will not be available after this date.
Please contact the hotel Reservations Team at 202-342-0444 or by e-mailing email@example.com and mention the United States Council for International Business (USCIB) room block using the following code: 062722OECD.
Rooms reserved without a processed registration will be cancelled in order to ensure space for confirmed participants.
USCIB’s Tax Committee is the most respected U.S. business association on international tax issues. USCIB is the only U.S. business association formally affiliated with the world’s three largest business organizations where we work with business leaders across the globe to extend our reach to influence policymakers in international markets that… click here to learn more.
For sponsorship opportunities, please contact Alison Hoiem (firstname.lastname@example.org).
In association with: