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Global Tax Seminar: International Tax Reform – Pillar Two

June 6, 2022 @ 6:00 PM - 7:45 PM

Zoom Seminar: Monday, 6 June 2022, 6:00pm – 7:45pm (AEST)

Registration open here.

IFA Australian Branch, the Tax Group (Melbourne Law School), and the Global Tax Symposium are proud to host Mr. Heydon Wardell-Burrus (Oxford Law School) and Dr. Suranjali Tandon (National Institute of Public Finance and Policy) in this online tax research seminar.

Our guests will both present their papers on the topic of Pillar Two.

MNE and State Strategic Responses to Pillar 2 by Mr. Heydon Wardell-Burrus

Pillar 2 creates a new set of incentives for both MNEs engaging in tax minimisation and States engaging in tax competition.

In Part 1, this paper argues that MNEs have five available strategies in responding to the presence of undertaxed income. It also argues that Pillar 2 creates two new ‘tax assets’ which can be strategically managed by MNEs to minimise their taxes.

In Part 2, this paper argues that Pillar 2 has left open a variety of channels through which States remain able to engage in tax competition. Not all States are equally able to take advantage of these channels and, accordingly, different States will be incentivised to adopt different strategies.

Part 3 of the paper argues that the pursuit of these strategies by both MNEs and States will have broader repercussions for the international tax system as well as the location of investment.

Impact of Pillar 2 on Developing Countries by Dr. Suranjali Tandon
Pillar 2 reform is design to fix the continued base erosion and profit shifting. The BEPS program was neither designed to nor was it able to fix tax competition, thus Pillar 2 shifts the narrative on international tax policy.
However, as countries agree to this reform it is important to examine what it means for tax policy in developing countries. The paper provides empirical estimates of countries that will be impacted by global minimum tax and finds that the reform does not deliver significant additional revenues to developing countries. A more important point worth examining is that with the possible withdrawal of incentives developing countries are expected to compete on other regulations. This may not be a viable alternative and can in turn compel countries to consider subsidies as well as reduction in indirect taxes in order to attract investment


Speaker: Mr. Heydon Wardell-Burrus

Mr. Heydon Wardell-Burrus is currently completing his DPhil in Law at the University of Oxford and is a researcher at the Oxford Centre for Business Taxation. he was previously a Director and Acting Assistant Commissioner at the Australian Taxation Office where he worked on corporate and international tax policy design and implementation. He was on the Australian negotiating team for the Pillars Project and a delegate to Working Party 11 (the body which negotiated the design of Pillar 2). Prior to joining the ATO, Heydon was a Senior Associate at Allens Linkalters. He has law degrees from the University of Sydney and Harvard Law School.

Speaker: Dr. Suranjali Tandon

Dr. Suranjali Tandon is Assistant Professor at NIPFP. She has published widely on topics in international taxation. She is a special invitee to the task force on sustainable finance, India and is an expert invitee to IFSCA’s sub- committee on sustainable finance related disclosures. She has worked in the past on many projects with the Ministry of Finance on key policy issues. She currently leads the institute’s work on sustainable finance and international taxation. She completed her PhD in economics from Jawaharlal Nehru University and was Chevening Financial Services Fellow 2019 at King’s College London.

Chair: Professor Miranda Stewart

Miranda Stewart is Director of the Tax Group and is a Fellow at the Tax and Transfer Policy Institute at the Crawford School of Public Policy, The Australian National University. She is a co-editor and author of several books, including Tax, Social Policy and Gender (ANU Press, 2017) and Income Taxation Commentary and Materials (with Graeme Cooper, Michael Dirkis and Richard Vann, Thomson Reuters, 9th ed., 2020). Miranda is a frequent public and media commentator on tax and budgeting and was named as one of the AFR’s 100 Women of Influence in 2018.

The Melbourne Law School Tax Research Seminars Online will be hosting the first series of Global Tax Symposium academic online seminars. The MLS Tax Research Seminars provide a regular and congenial online forum for presentation and discussion of new tax law, policy, and theory research. The usual format i s a presentation of the paper for 25 to 30 minutes, comments from a discussant and then ample time for questions and discussion. This seminar is by invitation only, please register your interest at law-tax@unimelb.edu.au to be included in the mailing list.

View past and upcoming seminar schedules here.


June 6, 2022
6:00 PM - 7:45 PM