2025 Agenda - Pillar 2 Summit DayMonday, 17 February 2025

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.