Impact of Pillar 2 on Corporate Tax Incentives and Incentives Post Pillar 2

Date -
Chapter - EMEA

Event Description

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MNEs usually benefit from various corporate tax incentives which could either be income-based or expenditure-based. The OECDs Pillar II rules could have an adverse effect on such incentives. In particular, traditional tax incentives (e.g., tax holidays, patent box regimes, R&D super deduction) are often no longer effective.

Against this background, the purpose of the roundtable is to discuss the impact of the Pillar II project on national corporate tax incentives and discuss the various corporate tax and non-tax incentives that governments (including the Swiss cantons) are willing to offer post Pillar II to both large and small MNEs.

After a welcome introduction by Martin Krivinskas (Partner, Deloitte), Prof. Vikram Chand (Professor, University of Lausanne) and Thomas Hug (Partner, Deloitte) will discuss the latest trends and developments around the world and Switzerland on this topic.


Prof Dr Vikram Chand is a Professor of Tax Law & Policy at the University of Lausanne (UNIL). He currently also serves as the Program Director of the Executive Program in Transfer Pricing offered by UNIL. His main areas of research, teaching and consulting expertise relate to Pillar Two (Global Minimum Tax Rules), Pillar 1 (Amount A and Amount B), Transfer Pricing, Tax Treaties, Tax Controversy Management and the intersection between International tax law and other areas of International Law.

Thomas Hug is Partner at Deloitte, and Head of Deloitte’s Swiss National Tax Office. Thomas also serves as a substitute judge at the Tax Appeals Court of the Canton of Zurich. With more than 15 years of experience in Swiss and international tax matters and a proven track record at the forefront of analyzing international tax developments’ impact on Swiss tax technical perspective, Thomas is a Swiss Certified Tax Expert.  Thomas is a lecturer in the Transfer Pricing Executive Program at the University of Lausanne and the Tax Accounting & Reporting Certificate Course of EXPERT Suisse, and is also an examiner for the Swiss Certified Tax Experts examinations.

Martin Krivinskas is a Tax Partner based in Zurich. Martin leads Deloitte's transfer pricing team in Switzerland and has extensive experience supporting global multinationals solve complex tax and transfer pricing challenges. Martin is a Chartered Accountant and a member of the Chartered Institute of Taxation.


Topics covered include:

  • Overview of different types of tax incentives

  • Impact of Pillar II (GloBE, QDMTT and STTR rules) on tax incentives

  • Post Pillar 2 incentives with a focus on Qualified Refundable Tax Credits (QRTC) and subsidies


  • 15:00 – 15:30 – Arrival, registration and coffee

  • 15:30 – 15:50 – Introduction by Thomas Hug

  • 15:50 – 16:50 – Open discussion

  • 16:50 – 19:00 – Networking apero

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