2025 Agenda - Pillar 2 Summit DayMonday, 17 February 2025

Moderated by Scott Klein, International Tax Principal at BDO USA, this panel of corporate tax leaders will discuss how Pillar Two has affected their tax provision and tax structuring processes, including examples of issues encountered and solutions, both short and long-term. The panel will also discuss some of the requests and developments in working with their financial statement auditors.

Pillar Two guidance requires that cross-border intercompany transactions be priced in accordance with the arm’s length principle. The commentary to the Pillar Two rules contains several nuances, however, that make applying this principle more complicated than might be expected. Furthermore, tax administrations can disagree among themselves and with taxpayers on what the correct arm’s length price should be. To help you navigate transfer pricing and Pillar Two, we will discuss how the two interact, including through year-end true-ups, APAs, tax authority audit adjustments, and other transfer pricing adjustments that can affect both the Transitional Safe Harbor and the GloBE tax calculations. Finally, we will discuss transfer pricing planning options that may be available to maximize the applicability of the Transitional Safe Harbor and/or optimize transfer pricing strategies in light of Pillar Two.

Designing and managing robust Pillar 2 compliance is built on a clear understanding of an MNE’s legal entity footprint and the terms of intercompany transactions, taking into account the impact of joint ventures, M&A transactions and changes in the group structure. This session will explain how legal workstreams need to be integrated into the planning and implementation of Pillar 2 compliance, including legal due diligence, opportunities for corporate streamlining and ongoing legal processes required.

Mergers, demergers, acquisitions, and joint ventures come with many Pillar 2 attention points. The Pillar 2 GloBE rules have an impact on such transactions and corporate restructurings for the different parties involved. During this session the impact of the Pillar 2 GloBE rules is discussed based on practical examples and consideration is given on items to address in SPAs and shareholders agreements.

Pillar Two poses data and reporting challenges that, for many, are greater than the cash tax risk from additional liabilities arising under the new rules. While the transitional safe harbours reduce the work required in initial years, most Pillar Two businesses are finding that some territories remain in full reporting. This may be a benefit, as it provides a chance to understand and address Pillar Two’s data requirements and put in place supporting technology before the need to scale up to full groupwide reporting after 2027. In this session we will look at the practical challenges to providing robust data quickly and easily, how technology can help, and what to do when technology on its own does not provide the full solution.