December 15, 2020

Mayer Brown Responds to Latest OECD Pillar Two Consultation


Firm Also Submits Comments on Behalf of the International Shipping Industry

Mayer Brown has submitted comments to the OECD’s latest public consultation document to Pillar Two—its proposed Global Anti-Base Erosion (“GloBE”) regime.

Our commentary was focused on the relationship between Pillar Two and the US global intangible low-taxed income (“GILTI”) rules. We recommend that the OECD consider GILTI a compliant regime for all purposes of Pillar Two so that no legislative changes to US tax law are necessary to bring the United States into compliance with GloBE.

Mayer Brown’s latest submission on Pillar Two follows our previous submission on Pillar One, which identified critical issues impacting the proposed expansion of nexus to digital and consumer-facing businesses. Pillar One and Pillar Two represent profound changes in the international tax landscape.

Separately, Mayer Brown also submitted comments on behalf of several trade associations with respect to the application of Pillar One and Pillar Two to the international shipping industry. We recommended that the international shipping industry be carved out of Pillars One and Two because of the existing and longstanding global consensus on how the industry is taxed.

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