With Pillar Two compliance deadlines approaching fast, business leaders can turn a new legal obligation into a competitive advantage by reimagining their approach to tax governance and refining or redesigning their target operating model. To meet Pillar Two requirements, companies must generate, gather and manage more data than ever before. The ability to leverage these expanded data sets can become a business advantage, transforming a regulatory burden into an opportunity for short and long-term planning and strategic business restructuring.

      Strategic implications of Pillar Two compliance

      For multi-jurisdictional businesses, tax compliance has traditionally been a significant yet manageable aspect of multinational operations. However, with the introduction of Pillar Two requirements, the landscape is undergoing a seismic shift. This framework part of the broader BEPS initiative developed by the OECD, imposes a minimum tax rate of 15% on multinational entities. This development is not just a routine change; it represents a fundamental transformation in how businesses approach tax obligations across international borders.

      As businesses scramble to adapt to these new rules, the additional workload is undeniable. Companies are now facing the daunting task of gathering, generating and managing more data than ever before, necessitating significant enhancements in their IT and tax technology infrastructures, as well as overall data gathering processes. These data sources are also more varied and no longer restricted to traditional enterprise resource planning (ERP) sources such as trial balances and general ledger accounts.


      How can Pillar Two compliance offer new business opportunities?

      This article explores how business leaders can turn Pillar Two compliance into a competitive advantage by innovating their tax governance frameworks and utilizing expanded data sets for strategic planning and restructuring efforts.


      Key takeaways

      • Business leaders can turn a new legal obligation under Pillar Two into a competitive advantage by reimagining their approach to tax governance and leveraging expanded data sets for strategic business planning.
      • Pillar Two significantly increases the compliance burden on MNEs. Companies need to establish a centralized process to ensure the timely filing of all returns and notices and to improve efficiency.
      • Companies must generate, gather and manage more data than ever before. Technology can play a key role by making the data collection process as streamlined as possible. These tools should output numbers but also provide custom inputs and custom scenario modeling.
      • The impacts of Pillar Two are large and complex. Best practices for readiness include a project plan covering impact assessment, data sourcing, operating model and compliance, among other things.
      • Pillar Two compliance is not just about meeting new legal requirements; it’s about reimagining the tax function as a pivotal component of modern corporate strategy.

      Our insights

      This podcast series addresses some of the most pressing issues and opportunities facing tax and legal functions in the modern business world, exploring key topics through interviews with leaders from tax, legal, and other areas of the business, from KPMG and beyond.

      The Fit for Pillar Two series aims to help tax teams of multinational enterprises within the scope of Pillar Two prepare for the upcoming wave of international tax changes by putting theory into practice.

      Insights and perspectives into BEPS 2.0

      Navigate the future of tax: pressing business issues and opportunities facing tax and business leaders today.

      KPMG's international tax practice is part of a network of professionals who can provide meaningful advice on cross-border tax matters.

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