Interplay between Pillar Two and Transfer Pricing Rules

Abstract

The international tax landscape has undergone significant changes with the introduction of the OECD’s Pillar Two GloBE rules, which aim to establish a global minimum corporate tax rate of 15%. This initiative is part of a broader effort to address the tax challenges arising from the digitalization of the economy and to curb the shifting of profits to low or no-tax jurisdictions. A critical aspect of these rules is their interplay with transfer pricing rules, a domain that has long been a cornerstone of international tax planning for multinational enterprise (MNE) groups. In this article, the authors analyse the points of convergence between Pillar Two GloBE rules and transfer pricing, the implications for MNE groups and a way forward.