OECD/G20 Two pillar solution: current situation and next steps from German and Belgian perspectives

Lieber Christian, Willkommen zu Brüssel Belgien!


Ladies and Gentlemen,

It’s my pleasure to host you here at this Symposium. I also would like to thank everyone for participating, digitally or physically. Special thanks go to our respective administrations for their preparation of this event. I am very happy to see that the event today has brought together private sector, public sector, as well as the academic sector in order to discuss and contemplate upon the topic at hand.

But why this topic? For years, we lacked predictability and fairness at international level in terms of taxation. Therefore the agreement that was reached at the OECD/G20 level is in my view historic. Never before we were able to bring so many countries together around such a sensible issue. For some countries we touch here at the basics of their economic model. For me this agreement is historic, and I do no weigh my words here. Those who follow the debates in the Belgian Parliament, and I suppose they are numerous, know that I have repeatedly stressed the historic character of the agreement.

We will be phasing out tax havens and ensure that multinational companies also pay their fair share.

But we still have some way to go before its entry-into force. This is why this symposium is not only timely but especially instructive for those who are dealing with the implementation of the two-pillar structure.

On political level, I fully support the efforts of our French colleague Bruno Le Maire to reach agreement at EU-Council level on pillar two. I have good hopes that we will reach this agreement in the coming period. And the we should accelerate at the national level.

On the pillar one, I hope we can make final progress on the model rules at the upcoming Ministerial in Paris at the 8th of June.

But at the same time, I am aware that the practical implementation of both Pillars represents a compliance challenge for in scope companies, as well as for both our tax administrations. I would also like to emphasize that it is of crucial importance that there is a good understanding between these two actors, with sound administrative guidelines, clear standpoints and sufficient dialogue. Predictability for all involved is crucial here. And the symposium today is part of this effort of consultation.  

The nature of the agreement means that we also need alignment between tax administrations. This also will foster greater tax certainty. But at the same time this is also a challenging exercise. Belgium and Germany are neighbors but for sure not identical. Christian, should I envy you that you have to deal with 16 Länder? And there are also clear differences in our tax system. But that is exactly the reason why we should engage, exchange and work together in implementing such a groundbreaking exercise like the implementation of the two-pillar solution.

From a Belgian point of view, we will also revise our structure of the international taxation services within our Administration. Especially at the start of this international taxation journey, it is crucial to provide the in scope taxpayers with the necessary administrative support and establish solid administrative practices. A well-equipped administrative service is essential to reach that goal.

So to conclude, I hope that the seminar today will be a starting point for further work on this issue, but also for further strengthening our already very strong bilateral ties. For Belgium, Germany remains our first trade partner. Creating and strengthening level playing fields between our two countries is therefore essential in my view.

Christian, I hope you can agree with me and it’s with pleasure that I give you the floor.