Consensus (of a sort) has finally been reached on the OECD’s two-pillar solution to international tax reform. Over 130 members of the OECD/G20 Inclusive Framework have signed up to the October 2021 framework agreement including pillar two’s global minimum rate of tax with model rules published in December 2021 (the model rules). So what happens now?
Unsurprisingly the focus has started to turn to implementation and what impact these rules will have in practice. This article focuses on M&A aspects: for a quick recap on how pillar two works see the panel below.
Pillar two is likely to have wide-reaching consequences for international M&A. From a...
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