Pillar Two: the consequences of staggered global implementation

With sufficient momentum behind the OECD’s Pillar Two project to introduce a global minimum tax, the initiative appears to be on the cusp of becoming a reality. Despite attempts to coordinate implementation to a global schedule, countries are adopting the rules in a timeframe that suits their legislative cycle and/or political imperative. Due to the interlinking nature of the rules, this staggered implementation cycle will create perverse outcomes for groups with a presence in early and late adopting jurisdictions.