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December 11, 2023

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.


Full text of EY article