BEPS Pillar Two is coming
With more than 140 countries signing up to Pillar Two under the OECD Inclusive Framework on Base Erosion Profit Shifting (BEPS), a global minimum Effective Tax Rate subjecting multinational enterprises with consolidated global revenue over €750M to an effective tax rate of 15% from 2024, implementation and legislation is gathering pace around the world. Multinational enterprises (MNE) should look to stay on top of these developments and prepare for the transition now in order to ensure readiness for the administrative, compliance and tax impacts under these new rules. The overall impact on tax teams can be significant with well over a hundred overlapping data points to determine Pillar Two top up tax (or qualified domestic minimum top-up tax (QDMTT)) and Global Anti-Base Erosion (GloBE) Rules.