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Miles Humphrey

Miles Humphrey is an International Principal Tax Advisor in Baker McKenzie's North America and EMEA Tax Practice Groups. Miles uses his deep knowledge of international aspects of US tax law and the interactions with UK/European tax law to act as a bridge between the UK and US to develop innovative tax planning solutions, often in response to tax law changes. Prior to joining the Firm, Miles served as the ICE Tax Desk Leader at Deloitte where he advised clients across several industries, with a particular focus on tax efficient financing and holding company structures; the ownership of IP; the location of treasury; risk and credit functions; the tax implications of restructuring; relocations and reorganizations and various treaty issues.

On 17 July 2023, the OECD/G20 Inclusive Framework on BEPS released a package of documents as part of its continuing effort to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy. On Pillar Two, this included further Administrative Guidance (including two new safe harbors) and the GLoBE Information Return, together with a report on the Subject to Tax Rule including a model treaty provision and accompanying commentary. We set out below our experts’ insights on these publications.

The OECD has provided further updates on its Pillar 2 initiative and some countries have responded with their intention to implement as early as 2024. In this episode, Ciro Meza, Miles Humphrey, and Allen Tan highlight key points of the new guidelines, questions that companies have been raising and how these may affect TMT companies. Since the impact of Pillar 2 will transcend various functions within a business, Baker McKenzie experts will share their insights on how TMT companies should react to these developments and when they should start taking action in light of the implementation timelines that have been announced.

Towards the end of last year, the European Union reached an agreement on its Pillar Two Directive, leaving a year for Member States to implement it in domestic law. The OECD also released its guidance regarding safe harbor and Penalty Relief, as well as public consultations on GloBE information Return and Tax Certainty for the GloBE Rules. Please join our experts, including those on tax policy, as well as economists and tax professionals across the globe to discuss the most recent updates and fresh insights on this topic each month. The first session in the series is on 8 February 2023.

While the OECD continues with its journey to modernize the global tax system under its two-pillar approach, many countries are now beginning to embark on the road to implementation of Pillar 2 and multinationals may need to prepare for its impact as early as 2023.
Join our panel of Tax professionals at the Baker McKenzie New York Office on 3 November 2022 for the next installment in our series of Pillar 2 events

In this newest episode of Baker McKenzie’s Global Tax Policy Video Series, Kate Alexander, Miles Humphries and Nick Evans discuss recent UK perspectives on Pillar Two. They also discuss what UK businesses are doing now to prepare for implementation of the proposed Pillar Two changes, despite a welcome delay to the UK’s implementation schedule.