This paper covers:
- The current state of play on the OECD's Pillar 2 program
- An overview of the Pillar 2 domestic law change proposals (the income inclusion rule and the undertaxed payments rule, together known as the GloBE rules) including identifying which entities are in-scope, the effective tax rate (ETR) calculation and identifying who pays the top-up tax
- An overview of the Pillar 2 treaty based changes (the switch-over rule and subject to tax rule)
- An analysis of implementation issues and next steps
- Consideration of the major impacts of the changes, especially on transfer pricing.