Global companies are facing potentially seismic shifts in the taxation of their operations, with national tax authorities seeking to keep pace with a rapidly digitalizing business environment. This was the backdrop when more than 250 global tax professionals, government officials and other tax experts gathered in Washington, D.C. June 3-4 for USCIB’s annual OECD International Tax Conference. This year’s event provided an especially timely window into the Organization for Economic Cooperation and Development’s work to develop tax policy recommendations to governments.
On May 31, the OECD released a work program to develop proposals for allocating a company’s profits among countries that re-balance source and residence taxation and also result in a global minimum amount tax paid on earnings. Drawing from the views of nearly 130 jurisdictions (far broader than the OECD’s membership of 36 countries), the OECD roadmap could result in fundamental changes to national tax laws and bilateral tax treaties, including a move to a much more multilateral approach to international corporate taxation.
USCIB President and CEO Peter Robinson asked conference-goers in his opening remarks: “How will a new consensus form around reallocation of taxing rights? Many interests will need to be balanced to achieve a solution that will be ‘globally fair, sustainable and modern,’ to quote the G20. The OECD also needs to keep global growth front and center.”
This sentiment was echoed by Bill Sample, tax policy advisory at Microsoft and chair of USCIB’s Tax Committee.
“Unlike the OECD’s earlier BEPS [base erosion and profit-shifting] exercise, this project will reallocate tax revenues among various countries,” he said. “It’s a political exercise, requiring compromise and the balancing of many competing interests among governments. One thing parties generally agree on is the need to keep these revenue shifts modest, and to have a predictable, sustainable model for global tax policy going forward.”
The conference was the 14th annual gathering on global tax policy developments convened by USCIB, in cooperation with the OECD and its official private-sector advisory body, Business at OECD (also known as BIAC).
The G20’s mandate
G20 leaders have tasked the OECD, with a long and distinguished history of work on international tax policies, to lead work a consensus-based solution to address the impacts of the digitalization of the economy, with a target of developing recommendations by next year.
The OECD’s effort represents “a fundamental rethink of the basics of the international tax system,” USCIB Vice President and International Tax Counsel Carol Doran Klein told Bloomberg News. “The scope could not be broader.”
G20 governments will review the OECD roadmap at a June meeting in Japan.
“Despite the fact that people have been listening to all the talk about this being the largest international tax project, it’s only when people read this and see how wide-ranging this is that they’ll be able to appreciate it,” Will Morris, chair of the BIAC Committee on Taxation and Fiscal Policy and deputy global tax policy leader at PwC, told Bloomberg. “It’s not just about changing technical rules. It’s about saying, essentially, the world has changed, and this system we’re looking at needs to change with it.”
Economist Ngozi Okonjo-Iweala’s keynote remarks focused on ways to improve the tax capacity of emerging markets, which are expected to receive a growing share of global private-sector investment in the years ahead.
Other panelists and speakers at this year’s conference included:
• Pascal Saint-Amans, director of the OECD Center for Tax Policy & Administration
• Martin Kreienbaum, director general for international taxation, German Ministry of Finance
• Chip Harter, deputy assistant secretary for international tax affairs, U.S. Treasury
• Dr. Ngozi Okonjo-Iweala, an economist and former finance minister of Nigeria
• Doug O’Donnell, commissioner of the Large Business and International Division, IRS
• Mike Williams, director of business and international tax, HM Treasury (UK).
It’s not too early to mark your calendars for next year’s OECD International Tax Conference, which will take place June 1-2 in Washington, D.C.