Preparing for Pillars One and Two: How Tax Administrations Can Get Ahead of the Game

Implementing and complying with the requirements of the OECD/G20 Inclusive Framework’s Two-Pillar solution presents enormous practical challenges for taxpayers and tax administrations.Not least of these is a complex data challenge with over 120 data points needed for Pillar 2 alone.To tackle these effectively,tax administrations should work with each other,and with taxpayers,to develop a coordinated approach drawing on the concept of Cooperative compliance.Such an approach should aim to reduce the administrative burden,increase certainty,and provide a joint learning curve for tax administrations and taxpayers.Developing the right data systems and training people to work with the data will take time and need to start now;if businesses and tax administrations wait until all the rules and regulations have been finalised,it will be too late.In addition,the Pillar 2 Model Rules do not provide for a multilateral mechanism to determine and allocate the top-up tax.The Belt and Road Initiative jurisdictions could consider working together to develop a binding mechanism to allocate the top-up tax between themselves.