What’s in it for Israel?

Israeli groups will probably be too small to pay Pillar 1 tax abroad. But large foreign groups may be exposed to paying Israel tax on Israeli Pillar 1 profits – but apparently not if their activity relates to Mediterranean gas exploration or regulated financial activities."} 70:{"position":13,"content":"

The amount of such Israeli profit remains to be seen. In particular, what about high past and present R&D expenses in California or elsewhere of big tech groups?

"} 71:{"position":14,"content":"

Comments on the Pillar 1 proposals

Double/multiple tax relief needs sorting out sooner rather than later."} 72:{"position":15,"content":"

What about indirect taxes, such as EU VAT and US sales tax following the Wayfair case in the US Supreme Court –these all aim to impose tax in the country of the consumer in addition to Pillar 1.

"} 73:{"position":16,"content":"

The situation regarding R&D and other expenses needs clarifying.

"} 74:{"position":17,"content":"

What about the USA generally? Does its federal tax legislation now meet OECD Pillars 1 and 2 requirements following the passing of the Inflation Reduction Act? What about state sales taxes?

"} 75:{"position":18,"content":"

The rules for allocating revenue and profit between countries seem subjective and open to alternative and inconsistent interpretations.

"} 76:{"position":19,"content":"

Will these proposals override the relatively new OECD multinational instrument (MLI) and bilateral tax treaties?

"} 77:{"position":20,"content":"

To sum up, the OECD is less effective than Robin Hood.

"} 78:{"position":21,"content":"

As always, consult experienced tax advisers in each country at an early stage in specific cases.

"} 79:{"position

The OECD Robin Hood package – Here's what you need to know

YOUR TAXES: The new OECD plan is an unfinished symphony.

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