Talking Tax

US Tax Carve-Out Beats Retaliation, OECD Business Rep Says

Jan 21, 2026
Christian Kaeser, Global Head of Tax at Siemens AG and co-chair of the OECD tax committee, discusses the recent global minimum tax agreement. He argues that the US carve-out benefits European companies by averting retaliatory taxes. Kaeser critiques the perceived unfairness of the deal but welcomes new safe harbors. He calls for simplification of EU rules, especially regarding controlled foreign companies. With Pillar One stalled, he dubs it a 'zombie' and advocates shifting focus towards growth and economic issues instead.
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INSIGHT

Avoiding U.S. Retaliation Was The Bigger Win

  • Christian Kaeser says the OECD package avoided severe U.S. retaliatory taxes that threatened European firms.
  • He views removing Section 899 as a bigger win than any competitive drawback from the side-by-side deal.
INSIGHT

Perceived Lopsidedness Yet Practical Acceptance

  • Kaeser acknowledges the deal looks "lopsided" in Europe but still prefers it to U.S. retaliation.
  • He applauds U.S. companies for being effectively exempted from parts of the global minimum tax.
ADVICE

EU Should Declutter Rules To Restore Balance

  • Kaeser urges the EU to simplify its rules, including reconsidering the CFC requirement under the Anti-Tax Avoidance Directive.
  • He says decluttering EU rules can neutralize competitive disadvantages from the OECD deal.
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