Pillar 2 Summit Day - 2024Thursday, 20 June 2024

Join seasoned tax professional, Rakhi Battacharia of Fiserv Inc, a Fortune 500 financial services company and global leader in the payments and fintech industry, who will be presenting an exclusive case study on how to get ready for Pillar 2 as a multinational corporation. Essential attendance for all heads of tax looking for peer-to-peer advice from those at the front line of implementation, facing common challenges and thinking through the complexity of the new rules with a "can do" approach.

The practical challenges of implementing a robust reporting environment are a key focus for most Pillar Two businesses right now. A working process whose requirements and conclusions can be communicated to auditors and stakeholders inside and outside the business is fundamental to success. This session picks up on the themes discussed in our session last year to look at the best practice emerging from implementation work, real-life challenges and potential pitfalls that could lie in wait before Pillar Two is fully bedded in. These include governance, timing implementation steps to balance financial reporting and tax requirements, and when and where automation can help.

Under Pillar 2 GloBE rules, there are many different types of Entities. Entities may qualify as for instance Partially Owned Parent Entity, Intermediate Parent Entity, Joint Venture, etc. The consequence of such qualification may have an effect on GloBE Income, jurisdictional blending and allocation of Top-up Tax. The qualification does not only affect the in-scope MNE group, but also the non-controlling shareholders. During this session we discuss the GloBE impact for non-controlled Entities by these shareholders.

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.