With international agreement having been reached on the key aspects of the OECD’s pillar two proposals, it is worthwhile to consider the impact these rules might have in practice in an M&A context.

Pillar two will affect financial modelling, as well as deal structuring and different bidders’ competitiveness. There may be new contractual protections to consider and a need for more post-acquisition co-operation. With the intention that the rules are implemented in 2023/2024, multinationals will have to get to grips with these issues quickly.

May Smith and Brin Rajathurai from our London Tax team consider these issues in further detail in the briefing available at the link below.

This briefing was originally published in Tax Journal on 1 July 2022.