BEPS 2.0 – Part 4: Pillar Two

The proposals under Pillar One and Pillar Two represent an ambitious attempt to transform the international tax system. However, as has been seen from the earlier parts in this series, a number of practical issues remain to be resolved under both Pillar One and Pillar Two before any tangible change will be seen at an international level. Such issues have failed to dampen the appetite of jurisdictions to address the problems to be solved by BEPS 2.0 and, indeed, some jurisdictions have taken unilateral action in the absence of an international solution. The fourth and final part of this series (albeit not the end of BEPS 2.0) considers the responses of different jurisdictions to the proposals under Pillar One and Pillar Two.