After the excitement surrounding the OECD's pillar one consultation, some might view the pillar two consultation as something of an anti-climax. Unlike pillar one, the launch was not heralded by a fanfare of announcements and webcasts but was quietly released on 8 November 2019. However, one should not underestimate the significance of this document which could have a fundamental impact on the way all multinationals are taxed, including the possible introduction of a global minimum rate of tax. The issues raised involve huge politico-economic questions for the 135 members of the Inclusive Framework. However, those looking for answers and a clear mapping of the road ahead may, for the moment, be disappointed.

This briefing was originally published in Tax Journal on 18 November 2019.