Expert Webinar

Topic

"Current Developments in Global Minimum Taxation Legislation: Pillar 2 versus Book-Minimum-Tax and GILTI – How German & U.S. Companies Are Affected and Can Act Now"
 

Speakers

Mr. David Sites, International Tax Partner at Grant Thornton LLP U.S.
Mrs. Christina Busch, Partner and Head of International Tax at Grant Thornton Germany
Mr. Norbert Miethe, Partner International Tax at Grant Thornton Germany
 

Registration

https://eventanmeldung.grantthornton.de/event/XYDQ833R3ZmkxRnh/einladung

Description

Germany, along with many other countries, is on track of introducing Pillar II rules into domestic law effective as of 2024. The so-called Pillar II legislation is supposed to ensure a global minimum taxation for multi-national groups and large domestic groups in the European Union and Germany. While the U.S. already has different rules in place that ensure an appropriate level of taxation for domestic and foreign earned income of multi-national companies, e.g. the 15% book minimum tax and the GILTI rules, there is currently little momentum of introducing Pillar II rules into U.S. law.

Our Expert Webinar will address how multi-national companies should approach the parallel existence of anti-low-taxation regimes in the United States and Germany, which are of similar intend, but of a different set of technical rules. It will, among others, discuss how Global Intangible Low-Taxed Income and the book minimum tax are to be considered for Pillar II purposes.

Finally, there is new case law available suggesting that U.S. investors in Germany may not suffer German withholding tax on dividends where the investment was made via a US S-Corporation. In the webinar, we will discuss how this affects typical S-Corporation structures and what actions are required to benefit from the advantageous case law.