What I can do for you

Pillar Two is comprised of the GloBE Rules (i.e., the Global Minimum Tax) and the Subject to Tax Rule (a tax treaty rule).
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The Global Minimum Tax is now a reality. Jurisdictions around the world are introducing legislation based on the GloBE Model Rules agreed in the OECD. The European Union already introduced a Directive that requires EU member countries to implement these rules. Other countries such as the United Kingdom, Japan, South Korea, and Canada, already have legislation, drafted legislation, or announced their intention to legislate.
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There is a lot of uncertainty on how these rules operate. Advisors are providing contradictory opinions to clients which is causing further uncertainty. I can support you in understanding these rules properly and can help you undertake or review your GloBE computations.
 
I can also help you monitor, early assess, and make sure your voice is heard regarding new developments that will impact your organization.
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Finally, companies that make cross-border payments need to consider the impact of the Subject to Tax Rule. I can also help you understand how it will impact your cross-border operations.

Foreigners investing in Mexico and Mexicans investing abroad need to understand the Mexican tax implications on their inbound and outbound investments. The effects of nearshoring are benefiting Mexico and these investments have Mexican tax and Pillar Two implications.  

I can help taxpayers understand all tax implications so they have the most complete information to make the best decision and comply with Mexican tax law. I can also help you understand how Mexican tax rules, such as, the Mexican tax transparency rules and tax treaties interact with other rules around the world.  

In addition, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) has been ratified by the Mexican Senate. This also has new tax effects in cross-border operations. I can help you understand what is at stake and help you comply with these new tax treaty rules.  

I have been working for governments and with governments for more than a decade. I can support countries in their analysis on whether to implement the Pillar Two Rules or modify their legislation in response to Pillar Two. I can also support governments during their draft legislation phase by making sure that the GloBE Model Rules are properly legislated and ensure that the country is ready to apply these rules during their implementation phase.  

I can also help governments in other policy decisions and potential tax changes in their legislation, such as adopting the recommendations from the BEPS reports, helping local governments adopt policies that can increase their tax collection, among other related work.

In today’s world, companies are socially pressured to maintain good tax practices to demonstrate that they are paying their fair share. The world of tax is complex and government officials and the private sector frequently have different views. I can bring a balanced and independent perspective to your organization to make sure you hear a different and impartial voice before making any important tax decisions.

In addition, I also provide other services such as:

• Engage or support in Tax Controversy and Dispute Resolution mechanisms (e.g., initiating a Mutual Agreement Process or testifying as an expert);
• Help companies in their cross-border Mergers and Acquisitions, including the impact in their Pillar Two computations; and
• Train in-house tax professionals in international tax matters.