On 20 December 2022, the OECD published an implementation package in respect of the implementation of the Pillar Two global minimum tax rules (Pillar Two). The package includes guidance on safe harbors; a public consultation document on the GloBE information return (information return); and a public consultation document on tax certainty.
This follows the statement on the components of global tax reform, agreed by more than 135 members of the OECD/G20 Inclusive Framework on BEPS (OECD inclusive framework) in October 2021, and the publication by the OECD inclusive framework of model rules for Pillar Two in December 2021 and commentary in March 2022.
In light of the above, we held a webinar on Thursday, 2 February 2023 where our tax experts discussed the following topics:
- Updates on the latest Pillar Two developments, including safe harbors
- Where businesses are in terms of their Pillar Two implementation journey
- How Deloitte is helping multinational companies, especially around safe harbor testing and data diagnostics
- Interaction with the new Corporate Tax law, especially impact on Free Zone companies
Speakers
Jan Roderick van Abbe
Jan is a Partner based within the International and M&A Tax team in Deloitte, Dubai. He has over 15 years of experience within direct and international taxation and transferred from Deloitte Singapore (and Deloitte Switzerland previously) to the UAE in 2016. Jan has substantial experience with inbound investments and structuring, providing tax and transfer pricing advisory in relation the relocation/set-up of companies, transfer of functions (IP and holding company), set-up of principal structures, permanent establishment analysis, application of tax holidays, tax planning around cash repatriation, treaty application and transfer pricing. Jan also has experience in negotiating and obtaining many advance tax rulings with the Swiss tax authorities Jan advises Middle Eastern multinationals regarding their legal and tax structures taking into account the developments arising from BEPS/economic substance requirements and other political developments focusing on risk management and asset protection. Jan leads Deloitte’s Economic Substance and Pillar 1&2 service offering across the region. Jan is regularly speaking at tax event such as IFA on international tax developments. Jan is a Swiss Certified Tax Expert and holds a Master’s degree in law from the University St. Gallen (HSG).
Tian Leong
Tian is an Assistant Manager in the International and M&A Tax team of Deloitte Middle East. He has over 10 years of experience both in the public sector and tax consulting. Tian has been based in the UAE since 2019. Tian has advised and supported various businesses with the Economic Substance Regulations (ESR) in the UAE since its inception including bespoke ESR advice, ESR compliance support and developing tax governance. Tian has also assisted various government authorities on ESR administration and enforcement. Tian is a member of Chartered Accountants Australia and New Zealand.
