With G20/OECD Inclusive Framework agreeing on Pillar Two, various countries have started the process of implementing Model Rules in domestic legislation. Pillar Two's income inclusion rule will take effect in the first countries as from 1 January 2024.
In the light of upcoming changes, TEI is hosting a series of webcasts to discuss the key aspects of Pillar Two from practical point of view.
Speaker biographies
Hans Pijl, IBFD
Hans dedicates his time at IBFD to the GloBE Rules. He was an international tax partner at Deloitte, and, simultaneously, a parttime judge at the Tax Court of Appeal. Hans taught/teaches international tax law at the Universities of Lausanne, Leiden, Amsterdam, Vienna and at the International Tax Center in Leiden. He was a member of the United Nations sub-Group of Experts for the Definition of the PE-Article. Hans started his career as a tax inspector (oil and gas, fraud). He studied philosophy, German literature (MA) and law (LLM, honors). He wrote some 100 articles on international tax law.
Nate Carden, Partner, Skadden, Arps
Nate is an international tax and tax controversy partner based in Chicago. He specifically concentrates on the tax aspects of ongoing business operations. He works with corporate and other clients across many industries, with a particular focus on life science, consumer products, media, and technology companies.
Marco Adda – BonelliErede
Marco Adda is tax partner with more than 20 years of experience in corporate tax, international tax and transfer pricing. He obtained his LLM in International and EU taxation at Maastricht University and he is a research fellow at UVA University (The Netherlands).
Francesco Parlatore - BonelliErede
Francesco Parlatore is a managing associate at BonelliErede and responsible for the development of the tax practice in Africa & Middle East. He has over 15 years of experience in advising multinational corporations in transfer pricing and international tax. Francesco studied business administration and law at Bocconi University of Milan (Italy) where he also obtained a master in corporate tax law; Francesco also holds an LLM in international tax law from Leiden University (The Netherlands). He has been also a lecturer at the International Tax Center of Leiden in transfer pricing and international tax.
Godfried Schutz, Partner, Deloitte The Netherlands, International Tax
· Godfried is a partner in International Tax team, where he co-leads the Netherlands BEPS/Pillar 2 focus group. He has over 20 years of experience in advising multinational corporations and private equity funds in establishing and structuring their international operations in the Netherlands, or in investing through the Netherlands into other jurisdictions. His focus is predominantly on the European and the Northern American market (United States & Canada). Godfried spent 9 years working in the Deloitte New York office on the Netherlands ICE desk.
Sander Kloosterhof, Partner, Deloitte The Netherlands, Tax Compliance & Reporting
Sander is a tax partner at Deloitte's with a focus on tax accounting and tax risk management. He also functions as (lead) tax accounting partner on large audit engagements. Sander has over 35 years of experience in (international) tax advising and over 15 years in tax accounting under IFRS and US GAAP. Apart from his work in relation to tax accounting and tax risk management, Sander is also still involved in the tax technical side of the business. In his role as chair of the Tax Opinion Commission he is involved in all high-end tax opinion work.
Loyens & Loeff
Charlotte Kiès - Partner International Tax - Amsterdam
Fabian Sutter - Partner International Tax - Zurich
Steffie Klein - Senior Associate International Tax - Amsterdam
Previous sessions slides
Deloitte
Session 1 - GloBE Income and Covered Taxes - 25 April 2023
Session 2 - ETR and Charging Mechanisms - 09 May 2023
Session 3 - Internal and External Organisations - 16 May 2023
Session 4 - Transition Rules and Compliance - 23 May 2023
Session 5 - The July AG - 26 Sep 2023
Session 6 - Reorgs - Impact of cross-border restructurings
Session 7 - Pillar Two Safe Harbours
Loyens & Loeff
Session 8- Constituent Entities and GloBE Income - 26 March 2024