For those in international tax planning, curious what you all think about the future in light of Pillar 1 and Pillar 2 (on top of beps measures like anti-hybrid rules, interest deduction limitations, etc.). Once companies adapt to the new regime(s) and assuming p1 and p2 are implemented broadly across jurisdictions, curious what type of planning/restructuring work will be of interest to clients post implementation. Short term I assume lots of planning work but curious on post-implementation

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Posting as :
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All companies will be good corporate citizens, no need to audit

funny

You should stay at government a bit longer. Try to work on regs or wait until something juicy comes out at least.

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Honestly I think P1 and P2 will shift companies’ focuses heavily towards maintaining compliance. Planning would be more of a “diligent compliance” exercise. Although planning/structuring in light of deals and transactions will gain more traction as a result.

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In the original message there is a lot of complexity. With complexity will come opportunity. Given the fact that all of this will evolve, there will be opportunities in the medium term. Agree that this will add more complexity to reporting and compliance in many instances. If things settle for many years with these frameworks, planning may suffer. If you think that things will continue to evolve, planning will evolve as well. No guarantees.

What area of IRS are you in?

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International

Lol, I should have added that I’m asking because I’m considering leaving govt (not because I want an inside scoop on near term planning techniques or structures).

Sure, but only if you tell us first what structures you are picking on right now 😉

Keep in mind P1 and P2 are just model rules and will likely be implemented slightly differently by each country. These differences will present planning opportunities.

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