Joint ventures and Pillar Two – Applying the rules

An increasing number of interpretative challenges have been identified for the application of the Pillar Two joint venture rules, as highlighted by Conrad Turley and Marco Dietrich.

The Pillar Two joint venture (JV) concept, first set out in the 2021 Model Rules, might be viewed as a narrowed version of the original idea, in the 2020 Pillar Two Blueprint, to subject associates (in which a multinational enterprise (MNE) had a 20 percent and above holding) to Pillar Two tax. The Pillar Two JV concept is quite particular and can differ from the JV concept under accounting standards. A Pillar Two JV will exist where an MNE has an investment in an entity which is equity met...

Sign in below or register now to read the full article

Authors: Conrad Turley, Marco Dietrich

Published Date: 17 November 2025