Pillar Two: Q1 2024 Checklist for US MNEs

The purpose of this note is to provide a didactic presentation of the reporting obligations, particularly aimed at the many "small groups" subject to Pillar Two regulations which are still at the beginning of their project and the French subsidiaries of foreign groups subject to this regulation.

This article summarizes the 2025 Finance bill, enhancing the global minimum tax regime with OECD instructions on deferred taxes and "transparent" entities, effective for financial years ending after Dec 31, 2024

We are thrilled to share with you a roundup of significant updates from December 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

Austria’s Pillar Two rules allow the ultimate parent entity to designate a "single taxable CE" for top-up tax, with the declaration to be filed via FinanzOnline by 31 December 2024.

The Belgian tax authorities (FPS Finance) announced that from 2 September 2024 multinational enterprises (MNE) and large domestic groups subject to the minimum tax for MNE groups and large domestic groups (Pillar 2) can start their Pillar 2 related prepayments.

The EU's Pillar Two Directive complements CFC legislation from ATAD. Austria adopted it in 2023, after implementing a CFC regime in 2018. The OECD later identified conflicts between the CFC legislation and Pillar Two.

We are thrilled to share with you a roundup of significant updates from June 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you a roundup of significant updates from May 2024 regarding Pillar Two, including insights into regulatory changes, compliance requirements, and implementation progress across various jurisdictions.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

With Pillar Two enacted in over 25 jurisdictions, it's crucial for calendar-year companies to understand the forecasted impacts on their Q1 2024 income tax provisions. Discover the checklist of action items curated by GTM, our member firm in the US, to navigate the complexities of new tax regulations.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

On 17 July 2023, the OECD (i.e. the Inclusive Framework, “IF”) published various new documents relating to the introduction of Pillar Two. In this article, we present an initial overview of the key aspects covered in these documents.

Find out the latest on the implementation of public CbCR in the Netherlands and what it means for multinational enterprises. Discover key details and important next steps in this newsflash.

Discover the latest insights from Lee & Ko, our trusted tax experts in South Korea, in their article published in Bloomberg Tax. Uncover the groundbreaking developments of South Korea's Pillar Two rules and explore their implications for foreign multinational enterprises operating in the country.

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

We are thrilled to share with you the latest issue of Pillar Two - Implementation Status Overview Worldwide!

Temporary and permanent reliefs bring simplifications.

On 20 December 2022, the OECD/G20 GloBE Inclusive Framework released its Pillar Two Safe Harbour and Penalty Relief guidance document. Read an article about the key elements of the transitional and potential permanent safe harbours from our tax experts in Belgium.

The Finance Ministry published an announcement dated 20 Dec 2022 on the base rate and margin notice for transfer pricing purposes in personal income tax (PIT) and corporate income tax (CIT). The announcement came into force on 1 January 2023.

15 December 2022 saw the Council of the European Union reach its unanimous agreement on the “Council Directive on ensuring a global minimum level of taxation for multinational and large-scale domestic groups” in a written procedure.

All EU member states to introduce global 15% minimum tax by the end of 2023!

Switzerland will implement the BEPS 2.0 Pillar Two minimum taxation by introducing a new minimum tax at the federal level.

Recently the US corporate alternative minimum tax (AMT) was resurrected by the Inflation Reduction Act of 2022. It is structured in a significantly different way than the previous one and only applicable to select corporate taxpayer’s. Meanwhile it is still unclear how the US AMT will interact with the OECD Pillar Two rules.

On October 24, 2022, the Netherlands published the draft bill on Pillar Two called ‘Minimum Tax Rate Act 2024’ (news item). This draft bill is open for public consultation until December 5, 2022.

Interview with Dieter Becker, Managing Director WTS Advisory

Overview of the procedural specifics and technical issues to consider in the five steps published by the OECD.

On 20 July 2022, the UK government published draft legislation on the Pillar Two Income Inclusion Rule (IIR) and its response to the public consultation on the UK Implementation of Pillar Two with the governmental position in the key areas.

To support companies in implementing and complying with these rules in the future, WTS relies on three different technical solutions for an integrated Tax Reporting and Pillar Two process.