The Complete Guide to Pillar 2
Everything multinational tax teams need to understand about the OECD GloBE rules, from scope and safe harbours to ETR calculations, top-up tax, and filing the GloBE Information Return. Written in plain language, with worked examples and practical guidance.
Why we wrote this guide
The OECD's Pillar 2 framework, formally known as the Global Anti-Base Erosion (GloBE) rules, represents the most significant change to international corporate taxation in decades. For in-scope multinational groups, the rules introduce a global minimum effective tax rate of 15% and a new layer of compliance that touches every jurisdiction a group operates in.
This guide walks through each stage of the GloBE compliance process, from determining whether your group is in scope through to filing the GloBE Information Return. Each chapter is designed to stand alone, so you can jump to the topic that matters most to you, or read through from start to finish for a complete picture.
What is BEPS Pillar 2?
The origins of the OECD/G20 Inclusive Framework, the two-pillar solution, and why 140+ countries agreed to a global minimum tax of 15%.
Chapter 2Who is in scope?
The EUR 750 million revenue threshold, what counts as an MNE group, excluded entities, and how to determine whether your organisation is affected.
Chapter 3GloBE Rules explained
The five-step compliance workflow and the three collection mechanisms (QDMTT, IIR, and UTPR) that bring the global minimum tax to life.
Chapter 4Transitional CbCR safe harbour
How the three safe harbour tests (de minimis, simplified ETR, and routine profits) can significantly reduce your compliance burden during the transition period.
Chapter 5Calculating GloBE income
Starting from financial accounting income, the required adjustments for excluded dividends, equity gains, foreign exchange, stock compensation, and more.
Chapter 6Covered taxes & adjustments
Which taxes count, how to adjust current and deferred taxes for GloBE purposes, recapture rules, and what is explicitly excluded.
Chapter 7Effective tax rate calculation
The jurisdictional ETR formula, what happens when the rate falls below 15%, and a worked example showing the computation end to end.
Chapter 8Top-up tax & SBIE
How top-up tax is calculated, the substance-based income exclusion with its payroll and tangible asset carve-outs, and the de minimis exclusion.
Chapter 9How top-up tax is collected
The QDMTT, IIR, and UTPR mechanisms explained: who pays, where, and the order of priority when multiple rules apply simultaneously.
Chapter 10Pillar 2 elections
A comprehensive guide to the five-year, annual, and one-off elections available under the GloBE rules, and how they can shape your compliance strategy.
Chapter 11The GloBE Information Return
What the GIR contains, who must file it, filing deadlines, and how tax authorities exchange information across jurisdictions.
Need help with Pillar 2 compliance?
Our platform automates the entire GloBE workflow, from safe harbour testing through to generating your information return with a complete audit trail. Book a demo to see how Pillar2 can help your team.