Substantively, the OECD project on the taxation of the digitalisation of the economy. Practically, even two years after my move to PwC I find I still have so much to learn. The combination of the two is completely invigorating (if sometimes completely exhausting!) and an unexpected bonus towards the end of my career.
If you could make one change to tax law or practice, what would it be?
Can I pick two? First, I’d make it much easier for people to ‘read’ the law (i.e. qualify by working in practice). A law degree should not be the only route in. My father read the law, and he was a much (much) finer lawyer than I could ever be. Second, I’d make it much, much easier to switch between private practice (whether in business or as an adviser) and the government. Both sides benefit, and mutual understanding and trust are greatly improved.
On the tax challenges of the digitalisation of the economy, (a) how should international reform be delivered, and (b) what do you think will actually happen?
On (a) I truly believe that the OECD process is the only (and best) hope of reaching a consensus agreement that will restore stability to the international system. I wish the timetable wasn’t as tight as it was, because to get deep agreement between 130+ countries will take time. Additionally, business (and other stakeholders) also need to be closely involved to ensure that the provisions achieve what governments want while not (at a minimum) adversely affecting economic growth, and, where possible, being pro-growth. But I do think that governments and the OECD are now beginning to work really hard on this.
On (b), the timetable worries me, and I am concerned that there is a possibility that in order to meet the deadline we get only high-level agreement, rather than the detailed agreement needed to ensure consistency of interpretation and application, etc. So, my hoped-for outcome at this point is that, towards the end of 2020, there has been sufficient progress towards agreement that the G20 allows the OECD more time to work on really filling out the details.
What advice would you give to tax policy makers?
Please remember that your job is not to be politicians. (Trust me, I truly understand the temptation from my years at US Treasury.) The tax policy maker must, of course, seek to carry out the political wishes of democratically-elected ministers. But, in doing that, they should exercise their judgment and experience as tax policy experts to embody those political objectives in tax policy that works best for the economy, and encourages international stability, etc. The true job of a tax policy maker is to be the intermediary between the raw political decision and the legislative and administrative outcome. That is a distinct and necessary function, that, perhaps, has become slightly attenuated in the BEPS years and since.
What about the future of tax?
One thing that fascinates me is how to we find a tax language that enables us to sensibly discuss some of the changes that are coming up in the economy/business world. I wrote about this in Tax Journal last year, but should we be focusing, for example, so heavily on ‘destination’ when the advent of artificial intelligence could make concepts such as source, residence and destination meaningless? It would make sense, before this wave rolls over us, to think about whether we can ‘future proof’ the new rules that we are currently designing.
And finally, you might not know this about me but...
I was ordained a priest in the Church of England ten years ago. While incredibly fulfilling, it occasionally raises eyebrows (‘Seriously – a tax lawyer and clergyperson?’). Interestingly, there is generally much more acceptance among my work colleagues of me also being a priest than there is among my clergy colleagues of me also having a secular (for profit) job. There’s a parable in there somewhere!
Substantively, the OECD project on the taxation of the digitalisation of the economy. Practically, even two years after my move to PwC I find I still have so much to learn. The combination of the two is completely invigorating (if sometimes completely exhausting!) and an unexpected bonus towards the end of my career.
If you could make one change to tax law or practice, what would it be?
Can I pick two? First, I’d make it much easier for people to ‘read’ the law (i.e. qualify by working in practice). A law degree should not be the only route in. My father read the law, and he was a much (much) finer lawyer than I could ever be. Second, I’d make it much, much easier to switch between private practice (whether in business or as an adviser) and the government. Both sides benefit, and mutual understanding and trust are greatly improved.
On the tax challenges of the digitalisation of the economy, (a) how should international reform be delivered, and (b) what do you think will actually happen?
On (a) I truly believe that the OECD process is the only (and best) hope of reaching a consensus agreement that will restore stability to the international system. I wish the timetable wasn’t as tight as it was, because to get deep agreement between 130+ countries will take time. Additionally, business (and other stakeholders) also need to be closely involved to ensure that the provisions achieve what governments want while not (at a minimum) adversely affecting economic growth, and, where possible, being pro-growth. But I do think that governments and the OECD are now beginning to work really hard on this.
On (b), the timetable worries me, and I am concerned that there is a possibility that in order to meet the deadline we get only high-level agreement, rather than the detailed agreement needed to ensure consistency of interpretation and application, etc. So, my hoped-for outcome at this point is that, towards the end of 2020, there has been sufficient progress towards agreement that the G20 allows the OECD more time to work on really filling out the details.
What advice would you give to tax policy makers?
Please remember that your job is not to be politicians. (Trust me, I truly understand the temptation from my years at US Treasury.) The tax policy maker must, of course, seek to carry out the political wishes of democratically-elected ministers. But, in doing that, they should exercise their judgment and experience as tax policy experts to embody those political objectives in tax policy that works best for the economy, and encourages international stability, etc. The true job of a tax policy maker is to be the intermediary between the raw political decision and the legislative and administrative outcome. That is a distinct and necessary function, that, perhaps, has become slightly attenuated in the BEPS years and since.
What about the future of tax?
One thing that fascinates me is how to we find a tax language that enables us to sensibly discuss some of the changes that are coming up in the economy/business world. I wrote about this in Tax Journal last year, but should we be focusing, for example, so heavily on ‘destination’ when the advent of artificial intelligence could make concepts such as source, residence and destination meaningless? It would make sense, before this wave rolls over us, to think about whether we can ‘future proof’ the new rules that we are currently designing.
And finally, you might not know this about me but...
I was ordained a priest in the Church of England ten years ago. While incredibly fulfilling, it occasionally raises eyebrows (‘Seriously – a tax lawyer and clergyperson?’). Interestingly, there is generally much more acceptance among my work colleagues of me also being a priest than there is among my clergy colleagues of me also having a secular (for profit) job. There’s a parable in there somewhere!
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