The long-expected arrival of the Pillar 2 tax system is upon us, with several countries already enacting all or part of the rules and Australia expected to enact the Pillar 2 rules with a start date of 1 January 2024. In addition to triggering accounting disclosure obligations and escalation of implementation projects, a new forward-looking mindset is needed to understand the impact on current and future M&A activity.
This session covers a practical update on the activity flowing from Pillar 2 enactment, with practical examples of unexpected outcomes, approaches to managing implementation and potential M&A impacts, including:
- An update on the global state of play, timelines, and potential transitional relief
- Accounting disclosures and choices which could impact Pillar 2 outcomes
- What an implementation project could look like over the next 12 – 24 months
- Approaching Pillar 2 with an M&A lens – what does diligence look like and what contractual protection might be needed
- Acquisition structuring considerations, now and looking forward to potential future changes; and
- Integration – practical pre and post-acquisition steps to ensure timely management of Pillar 2 obligations for acquired assets.