Pillar 2: what will be the impact?

The conference began with presentations and discussion with Pascal Saint-Amans from the OECD and Itai Grinberg. Researchers from the Oxford University Centre for Business Taxation (CBT) then presented their current conclusions from an ongoing research programme. And finally, the issues were debated by a panel of internationally-known participants from business, practice, and tax policy.

The agreement by the OECD’s Inclusive Framework to implement a global minimum tax has been hailed as a fundamental breakthrough in the reform of international tax. Janet Yellen, the US Treasury Secretary, said the “agreement represents a once-in-a-generation accomplishment for economic diplomacy”. Larry Summers, a previous US Treasury Secretary, said “this agreement is arguably the most significant international economic pact of the 21st century so far.”

Does the agreement – Pillar 2 of the OECD’s Two Pillar Solution – match up to the hype? The two key objectives have been to suppress both profit shifting by multinational companies and tax competition amongst countries. How far will Pillar 2 be successful in meeting each of these goals? How complex will implementation be? What outstanding issues are there?