A Tale of Two Pillars, Part II

Pillar Two is officially here, with forty-plus jurisdictions having enacted Pillar Two legislation. Despite the global progress made in the enactment of Pillar Two legislation, some questions surrounding the implementation of these rules remain unresolved. For example, how do jurisdictions determine if their domestic top-up tax regime is qualified and what happens if a domestic top-up tax regime is not qualified? Do the proposed incentives offered by certain jurisdictions enacting Pillar Two legislation undermine the purpose of Pillar Two? How might UTPRs, which are scheduled to go into effect in 2025, apply to U.S.-parented MNEs? Could the U.S. adopt a Pillar Two compliant regime in 2025? How might the UN’s parallel initiatives impact Pillar Two?

Join us as our co-hosts Kristen Gamboa and Gary Scanlon interview Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at the U.S. Department of the Treasury, to explore these issues and more on the latest episode of Inside International Tax.