Transfer Pricing Implications of Pillar Two Minimum Tax Rules

The Pillar Two Minimum Tax (or GloBE) rules are coming soon with many countries expecting to implement a Qualified Domestic Minimum Top-Up Tax (QDMTT) and/or Income Inclusion Rule (IIR) starting in 2024. So far, it has generally been the international tax planning or provision teams that have been at the forefront of MNEs’ response to Pillar Two. This article discusses four reasons why businesses should also keep a close eye on the transfer pricing implications of these rules and involve their transfer pricing teams.

Getting Country-by-Country Reporting Right

The Pillar Two Transitional Country-by-Country Reporting (CbCR) Safe Harbor is the first ...