Tax News Update    Email this document    Print this document  

December 11, 2023
2023-2042

Top 10 Most Common Pillar 2 Surprises for U.S. Multinationals

With more countries proposing and enacting Pillar 2 legislation, multinational enterprises may be familiar with the general framework of the Pillar 2 model rules and the extensive corresponding guidance that has been released to date. A closer examination of the Pillar 2 guidance, however, reveals unexpected issues that may come as a surprise to MNEs.

Jason Yen, Adam Becker, and Bona Chung identify 10 surprising possible outcomes of the application of the OECD’s Pillar Two initiative that they have encountered to date working with clients globally, particularly as they affect U.S.-based MNE groups.

Some of these issues may stem from unintended glitches in the rules and could perhaps be easily fixed by the OECD/G-20 inclusive framework in the future. Other issues result from deliberate policy choices in the rules, which would likely be more difficult to change. All can pose problems for U.S. MNEs if they are left unexamined in the context of each company’s individual facts and circumstances. Learn more in the attached EY article.

———————————————
ATTACHMENT

Full text of EY article

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2024, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement