Cross-border Tax Talks

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a Principal in PwC’s Washington National Tax Services Policy Office. She previously served as a Senior Advisor to the US Treasury Department, Tax Counsel for the US House Committee on Ways and Means, and Policy Director and Tax Counsel in the United States Senate. Doug and Beth discuss the OECD’s January 2026 side‑by‑side package: why consensus formed, how the side‑by‑side and UPE safe harbors operate, and why QDMTTs are taking center stage. They cover the simplified ETR safe harbor, the one‑year extension of the transitional CbCR safe harbor, elections and 2024–2025 compliance, enacted‑law accounting effects, the key footnote on UTPR allocation, and the new qualified tax incentives safe harbor, including both expenditure-based and production‑based credits, plus implications for inbound investment and the 2029 stocktake. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Hanan Abboud, a Dubai‑based International Tax and M&A partner who leads PwC’s Pillar Two efforts across the Middle East. Doug and Hanan discuss the Cooperation Council for the Arab States of the Gulf (GCC) region’s corporate tax landscape, including country differences, Zakat as a covered tax, and the prevalence of withholding and treaty networks. They then map Middle East Pillar Two adoption: Bahrain’s QDMTT, Kuwait’s QDMTT, Oman’s IIR, Qatar’s DMTT plus IIR, the UAE’s QDMTT, and Saudi Arabia’s lack of announcements. They dive into filing timelines, estimated payments, the evolving incentive landscape, the intersection with free zones, as well as practical pain points: data, provisioning, governance, and allocating top‑up taxes. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a principal in PwC’s Washington National Tax Services Policy group. Beth previously served as a senior advisor at the U.S. Treasury Department, tax counsel for the House Ways and Means Committee, and policy director and tax counsel in the U.S. Senate. Doug and Beth discuss contrasts between Senate personal offices and House committee roles; Ways and Means’ tax jurisdiction; and Beth’s experience moving from Congress to Treasury. Next, they jump into how DST disputes led to Pillar One and ultimately the emergence of Pillar Two; Build Back Better legislation; the Pillar Two model rules; U.S. credit design under Pillar Two; and the new administration’s response to Pillar Two. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Tadd Fowler, Senior Vice President, Treasurer, and Global Taxes at the Procter & Gamble company. Doug and Tadd discuss US tax policy after the Tax Cuts and Jobs Act, the OB3 package’s priorities and fixes (including interest expense apportionment, GILTI and FDII changes, and maintaining competitiveness), and why certainty still depends on ongoing policymaker education. They examine the OECD Pillar Two ‘side‑by‑side’ concept, the daunting Pillar Two compliance overlay on US rules, and P&G’s own Pillar Two posture. They also cover operating‑model design, incentives and foreign direct investment, how AI augments rather than replaces decisions, and the tax team’s priorities—business partnership, compliance productivity, people and capabilities, and advancing tax certainty through transparency and cooperative programs.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan, PwC UK’s International Tax and Treasury Network Leader and the UK’s Pillar Two lead. Recording in Barcelona at PwC’s Global Tax Symposium, they take stock of Pillar Two implementation and the much‑watched ‘side‑by‑side’ agreement. Doug and Matt discuss policymakers’ evolving openness to net CFC tested income (NCTI) coexistence, the UK’s 2027 legislative path with potential effect from 2026, the UTPR safe harbor expiration, practical frictions around POPE reporting, M&A data gaps, and the lack of a global dispute mechanism. They also examine transitional versus permanent safe harbors, potential consequences if Section 899 re‑emerges—including expanded BEAT exposure—and quick UK updates on the 25% corporate rate and the digital services tax.