The US Secretary of the Treasury has been ordered to investigate ‘whether any foreign countries are not in compliance with any tax treaty with the United States or have any tax rules in place, or are likely to put tax rules in place, that are extraterritorial or disproportionately affect American companies’ and to provide a report that will include ‘a list of options for protective measures that the United States should adopt or take in response to such non-compliance or tax rules’ by 20th March. Considering the US was heavily involved in shaping the BEPS Two Pillar approach, how significant do you think this report might be in relation to BEPS? In your view, are there any aspects or areas of the BEPS’ Two Pillar approach that could be improved upon if action is taken to reopen discussions?
