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OECD’s Pillar 2 global minimum tax proposal: Taking the pressure off transfer pricing podcast


This podcast covers:

  • The current state of play on the OECD’s Pillar 2 program
  • An overview of the Pillar 2 domestic law change proposals (the income inclusion rule and the undertaxed payments rule, together known as the GloBE rules) including identifying which entities are in-scope, the effective tax rate (ETR) calculation and identifying who pays the top-up tax
  • An overview of the Pillar 2 treaty based changes (the switch-over rule and subject to tax rule)
  • An analysis of implementation issues and next steps
  • Consideration of the major impacts of the changes, especially on transfer pricing.

Author profiles

Prof Richard Vann CTA
Richard is Challis Professor of Law at the University of Sydney and has taught at Harvard and NYU Law Schools and the Universities of Amsterdam, London and Oxford. Richard has worked in the past at the IMF and OECD and held many Government consultancies in Australia and elsewhere. He has been a consultant for specialist tax firm Greenwoods & Herbert Smith Freehills since 1985. Richard specialises in corporate and international taxation on which he has published widely both in Australia and internationally. - Current at 15 June 2022
Click here to expand/collapse more articles by Richard J VANN.
Mary Hu
Mary is an Associate, Greenwoods & Herbert Smith Freehills.
Click here to expand/collapse more articles by Mary Hu.


This was presented at 2021 National Transfer Pricing Conference .

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