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What Happens if the US Doesn't Implement Pillar Two?

There’s been a lot of speculation as to whether the US in particular will be able to enact legislation to implement Pillar Two in the near future.  This then raises the question as to exactly what would happen?
 
The answer depends on whether the ‘tipping point’ has been reached. The Pillar Two rules depend on a certain critical mass of jurisdictions implementing Pillar Two. Once this point is reached there would be significant disadvantages to not implementing Pillar Two. 
 
In this member’s article we look at the tipping point, the ‘common approach’ arising from the July 2021 statement by inclusive framework members and the impact of not implementing Pillar Two. 
 

The July 2021 joint statement by the members of the inclusive framework was an important moment. This gave broad political consensus to Pillar Two and was the origin of the ‘common approach’. The common approach means that the signatories to the July statement do not have to implement Pillar Two but they agree to other jurisdictions implementing the Pillar Two rules taxing low-taxed entities in their jurisdiction up to the 15% minimum tax rate.

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image showing example group structure if the US did not implement pillar two
Lee Hadnum

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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