How the BEPS Pillar Two rules could impact Oceania resources groups

In this episode of the EY Oceania BEPS 2.0 podcast series, host Tony Merlo is joined by Andrew Nelson and Liz Cullinan to explore the latest developments in the OECD BEPS Inclusive Framework’s Pillar Two initiative, including, in particular, the release of the Pillar Two Model Rules on 20 December 2021.

This episode focuses on the potential impact of these model rules on Oceania multinational groups operating in resources and other capital-intensive industries.

Other episodes in this podcast series explore some different aspects of the Pillar Two model rules, including a general overview of how the rules may affect Oceania multinationals [Episode 2], the potential impact on taxpayers in the financial services sector, [Episode 4] and what multinationals should be doing now from a tax systems perspective to be ready for the rules [Episode 5].

Learning outcomes

• Considerations of modified deferred tax principles in the Effective Tax Rate Calculation under the BEPS 2.0 Pillar Two model rules.
• Implications of countries implementing a Domestic Minimum Tax.
• Accounting challenges arising from the BEPS 2.0 Pillar Two model rules.
• Substance-based exceptions / carve outs for taxpayers.
• Consideration of implications of the BEPS 2.0 Pillar Two model rules to joint venture structures.

For your convenience, read the full transcript.