BEPS 2.0 and Pillar Two implementation developments

Originally published: January 2024

Next week, there’ll be a webcast that can update you on the current status of implementation of Pillar 2 (https://lnkd.in/efiavp-P). Now that it’s 2024, Pillar 2 has entered into force in a lot of jurisdictions.

I expect the webcast will talk about implementation in the EU (almost all done, although (1) Estonia, Latvia, Lithuania, Malta and Slovakia have opted for the deferral option available to them (https://lnkd.in/eKHTzUnZ) and (2) some EU countries are still lagging behind and may either implement with retroactive effect to 31 December 2023 or breach their EU obligations), Switzerland (which has been a bit Hot N Cold (https://lnkd.in/ezS2EPiE, hey, I used that song after all!) about Pillar 2 (https://lnkd.in/eyGeS3RBhttps://lnkd.in/erHK6_Amhttps://lnkd.in/e-StsWg6https://lnkd.in/ee5pEEfr) until finally adopting only QDMTT as per 2024 (https://lnkd.in/eNM4zq64), South Korea (implemented IIR and QDMTT, UTPR delayed to 2025 https://lnkd.in/etp9dCa6), Australia (announced to implement in 2024, but still no draft law out https://lnkd.in/e7UyXyza) and Vietnam (implemented and working on a FDI support fund https://lnkd.in/eAHPDxAs). But those are just the obvious ones (a full tracker is here: https://lnkd.in/eCxAG7p6). There could also be other developments we have further down the horizon and it would be interesting to see specifics of just how the implementation will work. For all these reasons, I will be tuning into the webcast. And you should probably too.

By the way, there’s also a separate webcast this week on Pillar 2 implications specifically for US MNEs (https://lnkd.in/eSQNmKvt).

Obvious disclaimers: this is not advice. These views are my own and do not necessarily represent my employer.

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