Navigating Complexities of Hybrid Arbitrage and Pillar 2 Regulations

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jesse Kavanaugh, an international tax partner at PwC Hong Kong who leads Tax Reporting & Strategy and co-heads PwC’s Asia-Pacific Pillar Two team. Formerly the global head of tax operations for a US tech multinational, Jesse brings both in-house and advisory insights. Doug and Jesse discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two legislation (pending when this podcast was recorded, but enacted on June 6, 2025) and HKMTT design; why many countries are shelving the UTPR; looming QDMTT deadlines; the critical difference between data-gathering and calculation engines; pitfalls that blow up transitional safe harbors, including management accounts, hybrid loans, interest-free debt and purchase-price accounting; and industry-specific challenges for shipping, airlines and real estate. Jesse closes with a simple message: start compliance prep now…registration and early QDMTT filings wait for no one.