A deep dive on Pillar 2 from an Australian perspective and a discussion on the Australian integrity measure: Denial of Deductions for Intangibles Connected with Low Corporate Tax Jurisdictions

The Australian Government recently announced it will implement key aspects of Pillar Two of the OECD/G20 Two-Pillar Solution. Join us for a conversation on Pillar Two and what it means from an Australian tax perspective, with Directors from the ATO Adam Peel and Michael Sapuppo, together with Alexandra Stead and David Schultz (from Baker McKenzie).

Topics to be covered include:

• ATO consultation process to date.
• Interactions with, and learnings from, other jurisdictions.
• ATO’s approach to compliance.
• Expected impact on Australian MNEs.

Date:
Thursday, 6 June 2024
Time:
5.30pm to 7.30pm (AEST)
Location:
Baker McKenzie office | Tower One – International Towers SydneyLevel 46, 100 Barangaroo Avenue, Sydney NSW 2000
RSVP:
Please register your attendance below. This is a hybrid (online and in-person) event.

This event is free for members and AUD 50 for non-members. Corporate members can include four attendees free of charge, and additional attendees may participate for free if they are individual members, or AUD 50 otherwise. Please note that membership is free for individuals under 30 and half price for individuals under 40. If you would like to become a member, please do so here.

Hybrid event

Registration form

Speakers

Adam Peel (Director, ATO – Pillar Two Implementation – OECD Programs, Treaties and Advice)

Adam has been responsible for the ATO’s implementation of Pillar Two since 2022. He is a Director in the project team with strategic responsibility for project management, corporate governance, client engagement strategy, development of systems, capability development, consultation and communication for the measure.

Adam is also a delegated Australian Competent Authority and previously had responsibility for the oversight of the ATO’s implementation and monitoring of OECD/G20’s BEPS initiatives, including providing early policy input in relation to Pillars. For ten years prior to this, Adam was a Director in Public Groups leading teams undertaking Engagement and Assurance activities, including risk reviews, audits, Mutual Agreement Procedures and Advance Pricing Arrangements on the largest multinationals operating in Australia.

Michael has been involved in the Pillars project for over 2.5 years and is a Project Director in the Pillar Two ATO project team responsible for ATO implementation. Michael leads a team that has a focus on technical/policy aspects of the Pillar Two measure including development of public advice and guidance and his team works closely with Treasury regarding law design and input at the OECD level. Prior to the Pillars project, Michael was a Technical Leader in Public Groups Engagement & Assurance where he led highly complex large scale audits and cases involving international transactions and structuring across a number of industries. Michael has also been in Public Groups Advice and Guidance leading rulings on international and corporate tax matters.

Alexandra Stead (Baker McKenzie)

Alexandra is a Senior Associate in the Tax Group at Baker McKenzie. Alexandra advises multinational and domestic clients on Australian taxation and international tax planning in relation to inbound and outbound investment. She also regularly assists clients with tax controversy matters. Alexandra works with a broad range of clients across the technology, infrastructure, property, FMCG and energy sectors. Alexandra holds an LLM (Taxation) and an LLB (Hons I) from the University of Sydney.

David Schultz (Baker McKenzie)

With over 14 years of experience in both the UK and Australia, David advises on cross-border tax planning, IP structures, corporate finance, and corporate reorganisations. Over the past several years he has had a particular focus on the OECD’s Pillar 2 rules, and he regularly advises on the impact of the Pillar 2 rules on financing and IP holding structures.  David has also published multiple articles in the UK Tax Journal as well as publications for the Tax Institute of Australia and in the journal ‘Taxation in Australia’.