Perspectives

Navigating Mergers and Acquisitions in the Era of the OECD Pillar Two Model Rules

Tax positions have always been a part of merger and acquisition (M&A) transactions, but the Organisation for Economic Co-operation and Development’s (OECD) Pillar Two Model Rules (Pillar Two) introduce a new layer of considerations. The impact on a target’s effective tax rate can affect the after-tax return on the investment, impacting the valuation of transactions. It is clear, therefore, that these rules will have wide-reaching implications for M&A, reshaping strategies, and decision-making processes for companies and investors alike.

Our article delves into the key tax implications of the Pillar Two Model Rules on M&A transactions, providing actionable insights and practical solutions to help MNEs manage these complexities effectively. By addressing these issues, companies can enhance their valuation models, tax due diligence processes, deal structuring, and overall strategic positioning within the global enterprise landscape.

Key Aspects Covered:
  • Pillar Two Charging Mechanisms
  • Valuations and Modelling
  • Tax Due Diligence
  • Tax Structuring
  • Contractual Protections
  • Financing Considerations
  • Integration and Post-Acquisition
  • Strategic Responses

 

Navigating Mergers and Acquisitions in the Era of the OECD Pillar Two Model Rules
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