Pillar 2 in tax business: a transformative shift in taxation landscape

Author Diede Kong-A-Sam
August 3, 2023

In recent years, global tax regulations have undergone significant transformations to address the challenges posed by digitalisation, cross-border transactions, and base erosion. Pillar 2, proposed by the OECD (Organisation for Economic Co-operation and Development), stands at the forefront of these changes, introducing a new framework aimed at ensuring fair taxation and preventing tax avoidance strategies by multinational enterprises. This article explores the implications of Pillar 2 as a new regulation and delves into its implementation and therefore possible challenges within the tax business.

Pillar 2 is part of the OECD’s broader project on Base Erosion and Profit Shifting (BEPS), which aims to tackle tax planning strategies that exploit gaps and mismatches in tax rules. Pillar 2, also known as the “Global Anti-Base Erosion” (GloBE) proposal, focuses on two interrelated rules: the Income Inclusion Rule (IIR) and the Undertaxed Payment Rule. These rules aim to ensure that multinational enterprises pay a minimum level of tax regardless of their jurisdiction.

Scope and impact of Pillar 2

Pillar 2 introduces a significant shift in the taxation landscape by addressing multinational entities’ tax liabilities more comprehensively. The new regulation applies to large multinational enterprises, typically with consolidated group earnings of EUR 750 million or more. By doing so, Pillar 2 aims to prevent profit shifting to low-tax jurisdictions, thus ensuring a fair distribution of taxable income and enhancing global tax certainty.

  • The Income Inclusion Rule under Pillar 2 requires that if a foreign subsidiary of a multinational enterprise is subject to low or no tax, the parent company must include a portion of the subsidiary’s income in its taxable income. This ensures that profits made in jurisdictions with low tax rates are still subject to taxation at the parent company’s jurisdiction, reducing the incentive for profit shifting.
  • The Undertaxed Payment Rule complements the Income Inclusion Rule by disallowing deductions or imposing withholding tax on certain payments made by a multinational enterprise to related parties in low-tax jurisdictions. This prevents the use of excessive interest payments and other deductible expenses to shift profits and artificially reduce taxable income.

The implementation of Pillar 2 poses several challenges for both tax authorities and multinational enterprises. One of the key challenges is the coordination and agreement among various countries to adopt the new rules consistently. The complexity of the rules and the need for detailed financial data may also present implementation hurdles for companies, especially for those with a multinational presence.

Navigating the new landscape

To comply with Pillar 2, tax teams need to gather comprehensive financial and tax-related data from various subsidiaries and jurisdictions. This data is crucial for assessing the tax implications of income inclusions and undertaking payment adjustments. Managing and analysing large volumes of data can be challenging, especially for organisations with complex structures and global operations.

Existing tax structures and planning strategies may need to be re-evaluated and adjusted to align with the requirements of Pillar 2. Tax teams will need to review intercompany transactions, financing arrangements, and transfer pricing policies to ensure they comply with the new regulations. This process can be time-consuming and require coordination with other departments within the organisation.

Assessing impact on Effective Tax Rate (ETR)

Pillar 2 is designed to establish a minimum level of tax that companies should pay regardless of their jurisdiction. Tax teams will need to analyse the impact of the new regulations on the company’s effective tax rate (ETR). Understanding how Pillar 2 will affect the ETR is essential for financial planning and budgeting, as well as for communicating with stakeholders.

Multinational enterprises operating in multiple jurisdictions may face higher tax risks due to the introduction of Pillar 2. Tax teams will need to assess the potential risks associated with tax audits and disputes in different countries. Managing these risks effectively requires expertise in international tax law and cooperation with local tax advisors.

Complying with Pillar 2 may entail additional reporting requirements and compliance obligations. Tax teams will need to prepare and submit documentation related to income inclusions, undertaxed payments, and any adjustments made to their tax authorities. Meeting these new compliance obligations may strain existing resources and necessitate process adjustments.

Pillar 2 is likely to evolve over time as countries adopt and refine their approaches to implementation. Tax teams must stay vigilant and continuously monitor changes to ensure ongoing compliance with the regulations. Staying informed about emerging developments and adjusting tax strategies accordingly will be crucial to meeting compliance requirements.


Pillar 2 represents a transformative shift in the tax landscape, addressing the challenges of profit shifting and tax avoidance by multinational enterprises. As countries move towards adopting and implementing these new regulations, businesses must adapt their tax strategies to meet the changing compliance requirements. By embracing the principles of transparency, fairness, and compliance, multinational enterprises can navigate the complexities of Pillar 2 and contribute to a more equitable global tax system.

While Pillar 2 is a significant step towards addressing tax challenges in the digital age, it presents several challenges for existing tax teams within multinational enterprises. Overcoming these challenges requires a proactive approach, including investing in specialized expertise, streamlining data management processes, and fostering collaboration between tax teams and other relevant departments. By proactively preparing for the implementation of Pillar 2, tax teams can navigate the complexities and ensure their organizations comply with the new regulations effectively.

If you would like to discuss the consents of this article further, require support in your hiring needs or would like to discuss your career and the current market, please contact Diede Kong-A-Sam.


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