Cross-border Tax Talks After-Tax KPIs: A SVP of Tax’s perspective
Dec 11, 2025
Tad Fowler, Senior Vice President, Treasurer, and Global Taxes at Procter & Gamble, shares insights on U.S. tax reform and its implications for multinational companies. He highlights the need for ongoing policymaker education to ensure tax certainty. The discussion delves into P&G’s unique after-tax performance metrics and the complexities of Pillar Two compliance. Moreover, Tad emphasizes the role of AI in augmenting decision-making and outlines P&G's tax priorities focusing on partnership, efficiency, and transparency.
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OB3 Complements 2017 Reforms
- OB3 made key international fixes that legislators wanted after 2017, including interest apportionment and GILTI improvements.
- Fowler sees OB3 as strengthening U.S. competitiveness while acknowledging policy remains politically influenced.
Certainty Requires Ongoing Policymaker Education
- Tax certainty never becomes permanent; companies must continually educate changing policymakers.
- P&G maintains engagement in policy discussions to protect pro-growth, investment-friendly rules.
U.S. Systems Make Pillar Two Challenging
- The U.S. already layers many anti‑BEPS rules, making Pillar Two potentially duplicative and complex.
- Fowler doubts Pillar Two will end the debate and stresses execution and sustainability concerns.