Deloitte Global leaders Chad Hungerford and Chris Oates reveal the key practical challenges of pillar two implementation while finding cause for optimism and even excitement in an exclusive podcast with ITR.

What motivates tax professionals to get up in the morning, and what keeps them up at night? Hungerford and Oates provide their insights in this wide-ranging podcast. The guest speakers draw on recent experience with tax authorities and clients to provide an inside track on the rapidly evolving pillar two landscape, with the significance of this moment resonating powerfully.

“Whilst this is a challenge,” Oates tells ITR commercial editor Phil Myers, “if you flip the coin, this is probably the most interesting new bit of tax legislation that has been introduced in my lifetime from a corporate perspective. And we see that reflected when we’re having conversations.”

The podcast explores the following areas:

• Emerging issues uncovered – Chad and Chris delve into the hurdles companies are finding;
• Priorities for companies – where businesses should be placing their focus at present;
• Common misconceptions – correcting widespread misunderstandings;
• M&A and growth plans – why pillar two must be factored in;
• Safe harbours and their future – why tax practitioners should “prepare for the worst and hope for the best”;
• Varying jurisdictional approaches – the “different flavours of implementation”;
• Technology transitions – whether now really is the right time to be considering new solutions; and
• The outlook – where is pillar two heading?

While the complexities and technicalities are addressed, the podcast also brings out the passion and excitement that drives tax professionals to tackle these challenges. The insights and practical advice on offer could help to arm you with the knowledge to navigate what, we are warned, could be a bumpy road ahead. As Hungerford says, “This is not something you can minor in – that you can spend a lot of time in every other area of tax and then just dabble with pillar two.”

Listen in and dive deeper into pillar two.

Dhruva tax experts Mehul Bheda, Kulraj Ashpnani and Ashish Agrawal review a whirlwind year for tax in India, in an exclusive podcast with ITR

It was a transformative year for tax in India, as 2023 saw a host of highly anticipated Supreme Court decisions and government policies impact the way both domestic and multinational companies do business. 

To help navigate this dynamic period, ITR editor Tom Baker spoke with three experts from Dhruva Advisors, partners Mehul Bheda and Kulraj Ashpnani and associate partner Ashish Agrawal, in an in-depth and colourful fireside chat. 

First on the agenda was analysing the fallout from a 2022 Supreme Court ruling related to the taxation of secondees from multinational groups to Indian entities. The speakers highlighted that multinationals need to be careful in the underlying documentation of expat secondment arrangements.   

Next, Agrawal reviewed a Supreme Court ruling from October 2023 regarding most favoured nation (MFN) clauses with India. The ruling stated that specific notifications by the Indian government was mandatory to invoke the MFN clause in India’s tax treaties. 

Agrawal warned of the implications: "[The Supreme Court ruling on most favoured nation clauses] could have severe implications for Indian companies and overseas taxpayers especially for past transactions, and the government needs to deal with it in a more pragmatic way."

Bheda then chimed in with a summary of recent case law regarding the buyback of company shares and the ensuing dividend tax considerations, before discussing changes to India’s ‘angel tax’ rules.

"The 'angel tax' is very peculiar. If you issue shares at a premium, they have to conform with 'fair valuation rules'”, Bheda argued. 

“If the share premium is in excess of fair value, the excess will be treated as income and taxed accordingly. It's a very punitive provision. There is nothing 'angel' about it!"

The session concluded with all participants attempting some crystal ball-gazing, and predicting what new tax controversies will arise in 2024, a crucial election year in India. 

About Dhruva 

Dhruva is dedicated to setting industry standards through exceptional service delivery. With strategic prowess, Dhruva has successfully managed numerous substantial and pivotal tax disputes and related matters within India.

Dhruva’s esteemed team includes 15 partners, five senior advisors, 11 associate partners, 30 principals, and over 300 exceptionally talented professionals.

Peter Olanday, director of consulting for vertical solutions at Vertex, talks to Alice Jones about using edge computing to manage real-time tax calculation as omnichannel shopping becomes increasingly common.

In this awards special edition of Tax Insights podcasts, ITR’s Commercial Editor Prin Shasiharan is joined by experts Chuck Kosal, Jennifer Deutsch and Kristine Riisberg of Deloitte.

In September 2021, Deloitte retained its title as the Americas Transfer Pricing Firm of the Year by ITR, while also achieving widespread national and regional success throughout the Americas across a number of categories including Tax Innovation and Tax Technology. The winners were announced in a virtual ceremony attended by several of the region's leading in-house and private practice tax professionals.

The experts discuss how Deloitte has stayed ahead of competition amid the challenges of doing business during the pandemic, outlining the importance of tax technology and innovation through practical examples.

This includes further insight into its strong pan-American regional network, its transformation strategy, and its accountability to clients.

Innovative compliance tools. New approach to reporting. Smart tech. ITR Asia-Pacific Tax Awards winners Jenny Clarke and Cristina Alvarez discuss how the team at KPMG is ‘re-imagining’ tax in the region.

In this awards’ special edition of Tax Insights podcasts, ITR’s Prin Shasiharan is joined by two KPMG leaders working in the Asia-Pacific region.

In August 2021, KPMG was announced as the Asia-Pacific Compliance and Reporting Firm of the Year by ITR, while also achieving widespread national and regional success throughout the region across a number of categories. The recognition marked the firm’s fourth consecutive triumph in the category.

The experts discuss how tax compliance has evolved over the last decade, including the impact of the KPMG’s renowned ‘Tax Reimagined’ offering, and the big picture challenges that multinational organisations face as they look to transform their tax functions. They provide examples of successful projects and provide advice for business leaders contemplating evolving their tax operations.

Tax Insights: Deloitte discuss the impact of tax transformation across the Americas

ITR Americas Tax Awards winners Chuck Kosal, Emily VanVleet and John Wells discuss how Deloitte is at the forefront of driving tax transformation, in a podcast.

In this awards special edition of Tax Insights podcasts, ITR’s Commercial Editor Prin Shasiharan is joined by experts Chuck Kosal, Emily VanVleet and John Wells of Deloitte.

In September 2020, Deloitte was announced as the Americas Transfer Pricing Firm of the Year by ITR, while also achieving widespread national and regional success throughout the Americas across a number of categories. The winners were announced in a virtual ceremony attended by over 1,000 tax professionals.

The experts discuss how Deloitte has stayed ahead of competition, outlining the importance of tax technology, transformation and innovation through practical examples. This includes further insight into its strong pan-American regional network, its talent component, and its accountability to clients.

The experts also explain the challenges of tax functions during the COVID-19 pandemic, the rise of data analytics, and offer their thoughts on how dependency on technology will evolve in the coming years.

ITR's senior reporter Mattias Cruz speaks with Ivan Ferreira, tax and customs director at Siemens Brazil, about the changes to the role of tax professionals, the impact of COVID-19 and managing mental health.

In August 2020 ITR announced the winners of this year's ITR Asia Tax Awards. As part of our new podcast series uncovering what success looks like, ITR are delighted to present an exploration into the business that won a range of awards including:

• Australia Tax Disputes Firm of the Year
• China Transfer Pricing Firm of the Year
• Hong Kong SAR Tax Firm of the Year
• Japan Transfer Pricing Firm of the Year
• New Zealand Tax Disputes Firm of the Year
• Singapore Transfer Pricing Firm of the Year
• Taiwan Transfer Pricing Firm of the Year
• Asia Tax Technology Firm of the Year
• Asia Tax Policy Firm of the Year
• Asia Tax Litigation and Disputes Firm of the Year

Hosted by Commercial Editor Prin Shasiharan, we invited EY Asia-Pacific Managed Services Leader , Jon Dobell and Albert Lee, EY’s Global Tax Technology and Transformation Co-Leader to discuss current business landscape, the challenges facing the market, their global technology solutions and what drives success in their team.

In the week that the OECD’s pillar one and pillar two documents were leaked, the tax world also grappled with more US regulations and a range of tax cuts and expected future rate rises.

Tax directors are worried that faceless e-assessments are creating a communication gap between taxpayers and the Indian Revenue Service (IRS) that could see the number of court cases rise.

In the week that Japanese Prime Minister Shinzo Abe resigned, the UK treasury denied rumours about cancelling its digital services tax, Facebook paid France €106 million in taxes and numerous VAT and COVID-19 announcements were made.

ITR’s Mattias Cruz talks to Luiz de Medeiros Ferreira, tax committee leader at IT company association Brasscom and tax head at IBM Brazil about sector-moving litigation, dispute resolution mechanisms and key tax issues in Brazil.

In the week that Joe Biden became the US Democratic Party’s presidential nominee, the tax world has been dealing with several key court cases, more transfer pricing (TP) measures, and trade developments. Listen to the latest developments and what's coming up next on ITR.

ITR's Danish Mehboob talks to Marc Mokrab, group tax director at Technicolor, about the three fundamental trends he sees influencing the tax function of the future: corporate responsibility, automation, and business partnering.  

ITR’s Mattias Cruz speaks with Emmanuelle Deglaire, academic at EDHEC, about the taxation of data, discussing the legal nature of a potential tax, the key challenges and the impact on multinationals. 

ITR Reporter Danish Mehboob sits down with Hany Elnaggar, head of tax for Nissan in the Middle East, to discuss the corporate outlook on the expansion of transfer pricing (TP) regimes in the Gulf Cooperation Council (GCC) countries, including more detailed TP audits in Saudi Arabia, and challenges to hiring the right tax talent in the region.

ITR Reporter Mattias Cruz sits down with Brazilian Federal Judge Renato Becho to discuss the difficulties of tax reform, problems at the federal court (CARF), his experiences of being a judge, and the legal difficulties for multinationals operating in Brazil.

In May ITR announced the winners of the ITR Europe Tax Awards, 2020. As part of our new podcast series uncovering what success looks like, ITR are delighted to present an exploration into our German Transfer Pricing Firm of the Year NERA Economic Consulting. 

Hosted by Commercial Editor Prin Shasiharan, we invited the firms Director, Philip de Homont and Managing Director, Dr. Yves Hervé to discuss the business, the challenges facing the German and European markets and what drives success in their profession.

ITR senior reporter Mattias Cruz asks Desmond De Battista, director of global indirect taxes at Burberry, on his approach to building a robust and flexible in-house compliance system that can withstand the tax demands of the future, the fashion company's approach to the UK's IR35 changes, and regional trends and key issues which are at the forefront for the indirect tax function.

ITR senior reporter Mattias Cruz asks Jayesh Rajyaguru, global head of tax at Wilmington plc, on his approach to managing the UK's IR35 changes, Brexit, becoming a tax director, digital requirements of the tax function and COVID-19.