As tax professionals, we are continuing to promote the case for global economic opportunities beyond taxation, especially in those areas where private companies, family offices and family trusts have proven to be important contributors to the economic, environmental and social health of their countries. Achieving the right balance between new taxation and incentives designed for growth will be critical for sustaining the long-term societal and economic performance in countries, territories and jurisdictions everywhere.
The implementation of the OECD’s BEPS Pillar Two rules and the potentially complex multi-jurisdictional reporting requirements that accompany these rules may affect private companies, family offices and trusts, that may unwittingly be caught in the rising tide of international taxation.
It has been assumed that the Pillar Two rules and the global minimum tax rate will apply primarily to large, public multinationals, however, the specific application and scoping rules and how they will be applied to large privately owned businesses, family offices and trusts is not yet clear.
Are private companies, family offices and family trusts that meet the minimum threshold and that have a foreign presence included in the 'multinational enterprise' definition?
Time is of the essence for family offices, trusts, personal holding companies and structures to prepare for what may lie ahead as the international tax landscape begins to change