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Global Markets:
Non Financial Risks and the Role of the Company’s Board and Expectations of Regulators and other Stakeholders
全球市场：
非财务风险和公司董事会的角色以及监管机构和其他利益相关者的期望
The Pillar Two Model Rules are designed to ensure large multinational enterprises (MNEs) pay a minimum level of tax on the income they derive in each jurisdiction where they operate. The Model Rules are a legislation template that jurisdictions are meant to translate into domestic law. Model Rules are integrated and supplemented by the Commentary and the administrative guidance, which have the role of helping jurisdictions implement the relevant domestic template legislation within the agreed timeframe and in a coordinated manner. The Pillar Two Model Rules have been designed as an overlay of tax rules that float upon a diverse range of tax systems. As such, many of the specific provisions of the Pillar Two Model Rules will not apply to all jurisdictions or each individual in scope MNE. Taxpayers in the scope of the rules compute their effective tax rate with respect to each jurisdiction where they carry out business operations and pay top-up tax for the difference between 15% and their effective tax rate. The eventual top-up tax is generally charged in the jurisdiction of the ultimate parent of the MNE. A de minimis exclusion applies where there is a relatively small amount of revenue and income in a jurisdiction. The Model Rules contemplate the possibility for the jurisdictions to keep their primary right of taxation over the income they generated by introducing their own domestic minimum top-up tax (QDMTT), which must mirror the Model Rules and which prevents (or is at least fully creditable against) any liability under Model Rules.
讲座时间及地点
主讲人
In a career spanning forty years Tim L’Estrange has represented companies, boards and individuals in some of the highest profile Australian domestic and cross-border corporate legal disputes and regulatory investigations. He has held senior executive positions in law and banking in Europe, the United Kingdom, the United States and Australia. He has been Managing Partner of one of Australia’s leading law firms and the Partner in Charge of two offices of global law firm Jones Day.
After completing his Bachelor of Commerce and Bachelor of Laws at the University of New South Wales, he became an associate to Federal Court Judge the late Honourable Justice John Lockhart AO QC. He joined Allen Allen and Hemsley in 1980. In 2001, Tim became National Head of Litigation and Dispute Resolution and a Board Member of Allens Arthur Robinson (as it then was named, now Allens Linklaters).
In 2003, Tim joined ANZ Banking Group as Group General Counsel and Company Secretary, becoming Managing Director for Europe and America in 2007 and finally being appointed as Group General Manager, Governance in 2010. In addition to having P&L responsibility in London, he worked closely with institutional and functional heads of the bank and liaised closely with global regulators, particularly in Australia, the US and UK. His broad in-house experience gives him a unique perspective in understanding disputes and regulatory requirements relating to all aspects of banking and finance and he regularly advises financial institutions.
Over his career, Tim has acted in significant matters for clients, often in “bet the company” style matters that impact reputations. Those matters cover a range of industries and legal areas including all commercial disputes, particularly in banking and financial services, mining and resources, gambling, oil and gas, maritime, aviation, family office, and sport. Tim joined Jones Day in 2013, as a Partner specialising in global dispute and regulatory investigations with an emphasis on corporate insolvency and banking and financial markets.
During his career spanning 11 years with Jones Day, he became the Partner in Charge of both Sydney and then Melbourne offices of the firm. Tim was the inaugural Honorary Permanent Secretary of the Court of Arbitration for Sport, (CAS) (Oceania Division) from 1995 to 2003 and he acted as the Tribunal Secretary in many arbitral hearings over his time with CAS, including during the CAS Ad Hoc Panel established for the Sydney Olympics in 2000. He also participated ex officio in meetings of the International Counsel of Arbitration for Sport (ICAS) in Lausanne. In 2024 Tim joined Newmans Row, a set or arbitral chambers in London established by Sir Bernard Eder and Blackhall & Pearl, a board advisory business. Tim is now an independent arbitrator, mediator and adviser.
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