Last week, the TALC BEPS Sub-Committee convened its first meeting of the year. There was a significant and detailed discussion on various matters relating to the EU Minimum Taxation Directive (“Pillar Two”). The various representative bodies had submitted a significant number of queries in advance of the meeting. There was also a discussion on the guidance on the new outbound payments defensive measures.
Outbound Payments Defensive Measures – draft TDM and discussion of submissions
Practitioners noted that they were generally satisfied with the draft TDM. While a number of comments were made at the meeting, the overall guidance should be of great benefit to taxpayers and their agents as they apply the new provisions.
Pillar Two: Update on draft Revenue TDM and discussion of submissions
Practitioners submitted a significant number of queries in advance of the meeting which were discussed fully at the meeting. A number of matters remain for discussion at OECD Working Group level (which Revenue is a party to). The discussion will be laid out fully in the minutes which can be found at the usual place on Revenue’s website in due course.