Cybersecurity threats and risks are increasing each day, and cybercriminals are getting more sophisticated in their attacks. Companies need to ensure that their data security measures keep up with ever-changing regulations and that they have protocols in place to deal with cyber threats, breaches, and ransomware attacks. Retail brands recognize that in an increasingly connected world, cybersecurity should remain a top priority.
On 3 October 2023, the OECD published the Multilateral Convention to Facilitate the Implementation of Pillar Two’s Subject to Tax Rule (STTR). As a reminder, the STTR is an integral part of the Pillar Two package, which consists of domestic rules (the GloBE rules) and a treaty-based rule, the STTR. One of the key differences compared to the GloBE rules is that the STTR is not limited to MNE groups with a consolidated turnover exceeding the EUR 750 million threshold.
Baker McKenzie has a long-standing history of participation and involvement in the UN Climate Change Conference of the Parties (COP), advising governments, companies and other entities on implementing the Paris Agreement and leading on the development of both international and domestic carbon markets.
The team will be on the ground in Dubai for COP28 and look forward to engaging in ground-breaking discussions with all key stakeholders to share insights and continue to offer cutting-edge advice to our clients. In the meantime, we have prepared a series of primers on what we expect to be some of the key themes for COP28.
A text of the Multilateral Convention to implement Amount A of Pillar One and additional explanatory guidance was released on 11 October 2023 by the OECD. This text reflects the consensus achieved so far, but is not yet open to signature and changes could still be made.
The proliferation of sustainability-related disclosures is a key trend in the prevailing socio-economic and legislative landscape. Tax – an increasingly important metric in the sustainability agenda – is starting to follow suit. In recent years, global, regional, and domestic measures have emerged with a view to increasing tax transparency, and this trend shows no sign of abating.
In this article, which is part of our ESG & Tax series, we outline the evolving tax transparency landscape and identify some of the key trends for businesses to get to grips with.
Artificial Intelligence (AI) is driving new business opportunities across a growing number of industry sectors, including consumer goods and retail. Enticed by its transformative potential, companies are actively exploring, experimenting, and deploying AI solutions in business processes, products, and services and are finding ways to derive business value from it. The emergence of generative AI capable of human-like text that can analyze vast amounts of data and create new content has caught the public’s attention and turbocharged interest in potential use cases in the CG&R industry.
It has become clear that flexibility is currency in the new working world and legal frameworks are evolving to catch up with the changing working culture. Four-day work-weeks, flexible working arrangements and the right to disconnect are all on offer to employees, giving the opportunity for better work-life balance, and giving employers a competitive edge in talent retention.
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.
Amount B was introduced as a “fixed return” on “baseline marketing and distribution activities” in the October 2020 Blueprint of Pillar One, and was seen as a critical component of the Pillar One deal
Following the long-awaited release of the consultation document on 8 December 2022 and subsequent public commentary received, the OECD/G20 Inclusive Framework on BEPS published a consultation document on Amount B on 17 July 2023, creating renewed momentum and putting Amount B back into the international tax spotlight.
July sure is a busy month in the Two Pillar world, with various developments to digest, including today’s final piece of the Pillar Two Administrative Guidance. Here are the links to the relevant July documents. Please watch this space for our detailed alerts being prepared by our experts.