Many multinational enterprises (MNEs) need to prepare for new tax legislation around the world that will impose a minimum rate of tax in each jurisdiction where the MNE operates globally. Based on Pillar Two of the Organization for Economic Cooperation and Development’s (OECD) base erosion and profit shifting (BEPS) project, these rules are complex and have taken effect in some countries as of January 1, 2024. As such, MNEs should act quickly to determine how they are affected. This article discusses practical steps MNEs can take to assess the impact of Pillar Two legislation on their organizations.
The Fit for Pillar Two series aims to help tax teams of MNEs within the scope of Pillar Two prepare for the upcoming wave of international tax changes by putting theory into practice. In this series, Christian Athanasoulas, Tax Practice Leader – Services at KPMG in the US, and Global Head of International Tax and M&A Tax at KPMG International, will provide his insights and draw on experiences from professionals in KPMG member firms worldwide. Articles in the Fit for Pillar Two series will build upon each other and are designed to guide companies through the phases of Pillar Two readiness, focusing on:
- Is your company ready for Pillar Two’s Global Minimum Tax?
- Unlocking global opportunities: Strategic tax responses and business restructurings in the era of Pillar Two
- Data, transformation and technology
- Compliance and reporting
- Pillar Two implications to mergers and acquisitions
- Pillar Two considerations for other departments in your organization
- Preparation for controversy and dispute resolution
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Christian Athanasoulas
Tax Practice Leader – Services, KPMG LLP, and Global Head of International Tax and M&A Tax,
KPMG International
