From the OB3 to the OECD: What Does the G7 Agreement Mean for Pillar Two?

On June 28th, the Treasury Department announced that it had reached an agreement with the other countries of the G7 – Canada, France, Germany, Italy, Japan, and the UK – to develop a “side-by-side” solution to Pillar Two, excluding US groups from the application of the UTPR and IIR in exchange for the removal of section 899 from the recent tax bill. What are the principles agreed to by the G7, and will the Inclusive Framework of the OECD fall in line? What are the next steps to implementing an agreement? Why are QDMTTs important to the agreement, and could they allow for the push-down of GILTI? How does the Trump administration plan to address digital services taxes going forward? What is the timeline for OECD agreement and for local country implementation, and how could that impact U.S. groups? Does the G7 agreement create or threaten the stability of the Pillar Two regime?

Join us as our hosts Gary Scanlon and Kristen Gamboa interview returning guest Michael Plowgian, a Principal in the KPMG WNT - International Tax practice, and Marcus Heyland, a Principal in the KPMG WNT – Economic & Valuation Services practice, to answer these questions and more on the latest episode of Inside International Tax.