EFAMA commented on IASB’s ED on IAS 12 (Pillar Two Model Rules). As the model rules drafted by the OECD establish that investment funds and investment entities should be carved out / excluded from Pillar Two, at first glance we expect them would not have a significant impact on our industry (at least on the strict product/funds side). While it is still to be confirmed what will be required from asset management firms and investors investing in funds to comply with the new rules, it is clear the analysis is highly complex. Some concerns and challenges may arise and the real impact of the proposals on the industry remains unclear. It is critical that if there are to be any additional or specific disclosure requirements, these should be subject to normal materiality considerations (we added some specific comments to the questions raised in the ED). It is in this context that EFAMA welcomes IASB’s proposal to introduce a temporary exception from accounting for deferred taxes arising from the implementation of the Pillar Two model rules.