The OECD-BEPS Two Pillar Solution is undoubtably one of the biggest developments in international tax that will have far reaching impact on corporates and economies alike, with 137 jurisdictions having agreed to implement the Two Pillar Solution under a common approach. While Pillar 1 looks to redistribute profits amongst market jurisdictions, Pillar 2 specifically aims to put a floor on tax competition through the creation of a global 15% minimum tax on corporates regardless of where they are headquartered or the jurisdictions, they operate in.

 

Furthermore, while Pillar 1 may impact a handful of global companies given that it would apply to MNCs with revenues of €20 billion or more and a profit margin of 10% or greater, Pillar 2 may impact many Indian MNCs given the comparatively lower threshold of €750 million.

 

The OECD released Pillar 2 Model Rules in December 2021 and commentary in March 2022. Rules for Safe Harbours and Penalty Relief were released in December 2022 as well as the package of technical and administrative guidance as recently as February 2023 which will be incorporated into a revised version of the commentary that is expected to be released later in 2023. This shows the commitment of OECD and member jurisdictions to stick to the timeframe of Pillar 2 rules entering into force in several jurisdictions by 2024. Member jurisdictions are also moving towards the adoption of Pillar 2, with many jurisdictions either passing domestic legislation to adopt Pillar 2 into their local tax laws or announcing their intention to do so.

 

It is now imperative that corporate taxpayers analyse the tax impact under Pillar 2 rules and compliances that might follow thereon. To help simplify this complex tax development and understand practically the impact of Pillar 2 on businesses, we are pleased to invite you to our Webinar-"Understanding Pillar 2-An International Perspective".

 

We would be joined by Anju Singh, RSM US- National Operational Transfer Pricing Leader and Juan Dosal, RSM Netherlands- Transfer Pricing Director, who are spearheading our Pillar 1/ 2 initiative at global level and extensively working on such projects. The agenda of the webinar is as under:

 

Introduction

 

23rd February 2023

11.30 am to 1 pm (India time)

Pillar 2-Technical Overview

Practical Approach and Case Studies

Q&A

 

Webinar Details:

 

Date: Thursday- 23rd February 2023  

Time: 11:30am – 1pm (India Standard Time)

Webcast registration link: https://us06web.zoom.us/webinar/register/WN_mWq3UMcYRImVS6IBQM1X2A

After registering, you will receive a confirmation email containing information about joining the webinars. Participants are requested to join by 11:25 am for efficient registration.

We look forward to having you at this very exciting event and hope you will enjoy this webinar of contemporary relevance.