Pillar Two Reloaded: Second Round of OECD Guidance

The OECD released a second round of Pillar Two administrative guidance on July 17^th, and although it focuses on five main topics, in-scope companies will have a lot to consider before the next set of guidance becomes available later this year. In this episode, we explore a few of the key issues addressed in the July administrative guidance, including the treatment of transferrable credits and the application of certain GloBE safe harbors. In addition, we discuss the current state of play regarding Pillar 2 implementation across the world and what to expect in the final stretch of 2023. Not surprisingly, many questions still remain as we near the end of 2023. Will South Korea delay the effective date of its UTPR? Will countries historically viewed as “investment hubs” change their tax laws in response to Pillar Two, short of full implementation? What can we expect in terms of additional guidance from the OECD this year?      

Join us as our hosts  Gary Scanlon and Kristen Gamboa dive back into Pillar Two with Marcus Heyland and Kevin Brogan to explore these topics and more on the latest episode of Inside International Tax.