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New Pillar Two Guidance, New Considerations for U.S. Multinationals


On February 2, 2023, the OECD released agreed Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), as part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) in implementing the two-pillar solution to address the tax challenges arising from the digitalization of the economy. The guidance is intended to ensure coordinated outcomes and greater certainty for businesses as they move to apply global minimum tax rules from the beginning of 2024. In some instances, the clarifications have a material impact on the application of the Pillar Two rules, particularly for U.S. multinational groups, and should be factored into any modeling currently being undertaken.

KPMG LLP is pleased to invite you to a 90-minute webcast on the new guidance, presented by professionals from the KPMG Washington National Tax practice. Following a summary of the release, the following areas that may affect U.S. multinational groups will be explored:

  • Treatment of GILTI and Subpart F, including interactions with Qualified Domestic Minimum Top-up Tax (QDMTT) and allocation rules for GILTI taxes
  • Treatment of overall domestic losses (ODLs)
  • Treatment of tax credits arising from equity investments
  • Clarifications to the transition rules.

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