On December 20, 2021, the OECD published the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) report, involving 137 countries. The report describes the so-called Pillar Two rules and introduces a 15% global minimum tax for Multinational Enterprises (MNEs) with an annual revenue of above €750 million. On December 22, 2021, the European Commission published a draft EU Directive to incorporate the Pillar Two rules into EU law.
This memorandum outlines the main considerations for companies in scope of the Pillar Two rules so that they will be ready for this additional compliance obligation. To help organizations prepare, we will look at these considerations from three different perspectives, i.e. a tax director’s perspective, a tax assurance perspective and a data management perspective.