Although the United States has not yet enacted legislation implementing Pillar 2, other OECD members have committed to enact legislation during 2023 that generally would take effect beginning in 2024. Large MNEs with operations in any jurisdiction that adopts the rules will likely be subject to the minimum tax provisions regardless of whether the United States fully adopts its own Pillar 2 legislation. This article discusses the general principles of Pillar 2 and highlights actions that U.S. MNEs should consider taking now to assess the potential impact of Pillar 2.

BDO’s Matt Williams, David Little and Dillon McDaniel provide guidance for MNEs in their article in The Tax Adviser.