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ARTICLE · 20 JANUARY 2025

What Does 2025 Hold For The Global Minimum Tax (Pillar Two)?

A&O Shearman
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Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds.

GlobalTax
Brin Rajathurai
Brin Rajathurai
Ryan Bray
Ryan Bray
Ishtar Sancho
Ishtar Sancho
Matthew Brown
Matthew Brown
Maciej Kulawik
Maciej Kulawik
Juan Jose Sanchez
Juan Jose Sanchez
Jose Rego
Jose Rego
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Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with widespread implementation, with the OECD predicting in October 2024 that approximately 90% of multinationals in scope of Pillar Two rules will be subject to the 15% minimum corporate tax rate by 2025. As we move into 2025, there look to be more headwinds as more countries grapple with the detail of Pillar Two, the UTPR starts to take effect in some jurisdictions, the U.S. heads into its new administration and Pillar Two faces a potential challenge from the UN. Can Pillar Two continue to weather the storm?

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