On 18 June 2020, the OECD Secretary-General issued a statement regarding recent statements and exchanges in relation to the ongoing negotiations to address the tax challenges of the digitalisation of the economy. Most notably in this respect is that the United States seem to have sent a letter to certain European countries (France, Italy, Spain and the UK) warning them that the discussions regarding the OECD’s Taxing the Digital Economy initiative has reached an “impasse” and that the US will put retaliating measures in place when these countries press ahead with the local implementation of Digital Service Taxes (DSTs).
This message follows after the United States announced that they opened trade investigations into proposed and enacted DSTs of nine countries and the EU.
The OECD Secretary-General now recommends in his statement that all members of the Inclusive Framework on BEPS remain engaged in negotiations, with the goal of reaching a multilateral solution by the end of 2020. According to the Secretary-General, failure to reach a multilateral solution would lead to the implementation of unilateral measures by countries that could trigger tax disputes, increase trade tensions, and further damage the global economy. The next inclusive framework meeting where a consensus-based solution is expected to be discussed is planned for October 2020.
If you would like to hear more on this topic, please register for our webinar on Tuesday 30 June during which Deloitte`s Swiss and US tax experts will discuss the developments at OECD level in more detail, focusing on the practical aspects of managing the potential impact of Pillar One.
If you would like to discuss more on this topic, please reach out to our key contacts below.
Key contacts
Salim Damji - Partner, Transfer Pricing
Salim Damji joined Deloitte Switzerland as a Transfer Pricing and BMO Partner in our Zurich office from another Big Four firm in Switzerland. Salim has been a Big Four firm’s partner for approximately 14 years. He primarily works with Swiss groups to assist them in developing transfer pricing models which are globally sustainable, Advance Pricing Agreements, Mutual Agreement Processes, and Business Restructuring issues. Salim, who works extensively in the field of Intellectual Property, started his career in the UK, before moving to Switzerland in 2005 and worked in the UK, USA, and Switzerland. He holds degrees from Oxford University and Southampton University. .
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Martin Krivinskas- Partner, International Tax
Martin is an international tax partner with 20 years experience working on international tax matters. He has worked extensively with global multinationals, with a particular focus on helping international group’s mitigate tax risk and manage their effective tax rates. Martin has significant experience of supporting clients with a wide range of transfer pricing and international tax matters and is part of Deloitte` s Global Value Chain Alignment leadership team. Martin`s clients are predominantly in the life sciences, industrial products and consumer products industries.
Martin is a Chartered Accountant and a member of the Chartered Institute of Taxation
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Jeff Smoleroff - Director, Transfer Pricing
Jeff is a Director in Deloitte Switzerland’s Transfer Pricing team. Jeff has 15 years of transfer pricing experience working within Big 4 in the US and in Switzerland, providing tax and transfer pricing advice and services to multinational enterprises (MNE) based both in Switzerland and abroad. Through his 15 years of tax/transfer pricing experience, Jeff has significant experience assisting MNEs with both transfer pricing planning and compliance, including working with MNEs on business restructurings; IP planning; value chain analyses; BEPS-compliant transfer pricing documentation; and assisting companies with certain key international provisions of Swiss and US Tax Reform.
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Arjan Oosterheert - Manager, Transfer Pricing
Arjan is a Manager in the Transfer Pricing team of the Zurich office and has an international corporate tax background. He predominantly advices his multinational clients on the Transfer Pricing aspects of the adjustments they make to their business models. Arjan is experienced in developing and implementing pragmatic Transfer Pricing policies, negotiating bilateral APA’s and preparing Transfer Pricing documentation. He has furthermore worked on a series of merger & acquisition transactions, including the related post merger integration projects.
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