Trending Now

Hong Kong Updates Global Minimum Tax Bill for OECD Administrative Guidance and Other Updates

South Korea’s updated Enforcement Regulation and Enforcement Decree provides for OECD Administrative Guidance Updates

OECD Administrative Guidance Matrix: Updated to April 23, 2025

Poland to Issue a Draft Bill to Implement Aspects of the OECD Administrative Guidance

Why MNEs Should Reassess SPVs in Light of Pillar Two

Summary MNEs use Special Purpose Vehicles (SPVs) for a variety of reasons, some of which are not tax-related.

However, the nature of the Pillar Two GloBE Rules means that in some cases, SPVs can be extremely inefficient from a tax perspective, particularly if they are located in a low-tax jurisdiction. They could result in excess Pillar Two top-up tax for the group.

In this article, we look at the reasons why this could be the case.

What is the Issue?

Let’s take this scenario:

Sign into your account to access this analysis

Login/Register Please login or register to view this analysis.

Lee Hadnum

Lee is a qualified Chartered Accountant and 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.

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.

Necessary

Always Enabled

Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Others