Pillar 2 Summit Day (Agenda Subject to Change)Thursday, 19 June 2025

This session will delve into the progress of (and challenges related to) the adoption of the OECD's global minimum tax framework. It will cover legislative advancements in key jurisdictions, highlighting differences in implementation timelines and legislative design, as well as interactions with other local and foreign tax regimes. The discussion will also address practical issues such as administrative guidance, transitional rules, and the compliance burden on large businesses.

In this hour-long panel session, international tax leaders will present a short case study on on Pillar 2 implementation and compliance in practice. Speakers will explore how Pillar 2 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 interacting with their statutory auditors.

Following the Trump Administration's Presidential Memorandum opposing Pillar 2 right after the January election, the House of Representatives have reintroduced bills as countermeasures against other countries extraterritorial measures that would adversely affect US multinationals. As countermeasures, the legislative proposals may increase the relevant US tax rates, deny certain treaty benefits and/or unfavorably impact the mechanism by which the base erosion and anti-abuse tax ("BEAT") applies to various non-US owned entities. These rules may also prompt offsetting tax changes in other countries with respect to Pillar 2 impacts in the US. The extension proposals for the US Tax Cuts and Jobs Act ("TCJA") may also impact Pillar 2 legislation globally. This panel will discuss their thoughts for the US role in the global Pillar 2 process, and interaction of the US tax rules.

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 optimise transfer pricing strategies in light of Pillar Two.

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.