Rishi Sunak is understood to have raised the exclusion of the financial services sector from the application of the 15% tax agreed by the G7 this weekend, pointing to the capitalisation reality of businesses in that sector as the reason why financial services providers already pay the right level of local tax. He also indicated that "EU countries are in the same position".
On the other side of the pond, the Biden administration is required to give the G7 a run for its money, to ensure that it isn't just the big US firms - who dominate the global big tech field - who get pushed onto the rails. There is an added possibility that the biggest companies might actually end up paying less under Pillar One than they do under the current digital services regime because, e.g., Amazon's business-wide margin hovers around 7-8% and it is envisaged that the new Pillar One tax would apply only on profits above 10%.
All this adds up to a difficult process of negotiation which is only just beginning.
For Gibraltar, there's a possibility that such an exclusion gives it an advantage in the context of other finance centres. With its mix of financial services and online gaming and gambling companies, bolstered by the continued growth in the establishment of startups in the dlt financial services space, as well as its unique advantage of offering market access to the UK, Gibraltar could well be the dark horse - the one to watch...
The rationale for excluding the financial sector was set out in October 2020 in a pillar one plan that said financial services were a special case because they were generally required to have appropriately capitalised entities in each jurisdiction and therefore paid the right level of local tax.