122 Data Points for Pillar Two Systems Implementation
Identifying the data points required to apply the Pillar 2 rules is the first step in any tax data mapping MNEs undertake. We list the key 122 data points.
Interactive Map: Countries with 2022 CIT Rates Below 15%
Our interactive map breaks down worldwide corporate income tax rates to identify jurisdictions with a headline CIT rate below the Pillar Two 15% rate.
Germany beginning implementation of Pillar Two
Item 17 of the third relief package (issued September 4, 2022) states that Germany will start implementing Pillar 2. Read our initial thoughts on its enactment.
Global Digital Services Tax (DST) Tracker
Our Global Digital Services Tax Tracker allows you to stay up to date with international digital service taxes. Cited and with links to domestic legislation.
Interaction Between OECD Pillar 1 and Pillar 2
Whilst Pillar 1 and Pillar 2 are separate and independent of each other, there are areas where they overlap, most notably the inclusion of Pillar 1 tax for Pillar 2 purposes and the overlap in some of the adjusted profits definitions.
OECD Pillar One Modelling Tool
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
Pillar Two: Investment Companies Top-Up Tax Calculator
Our Investment Companies Top-Up Tax Calculator models the impact of Pillar Two in a jurisdiction where there are a mix of investment and non-investment companies.
A Review of the Amount A Double Tax Relief Rules
The Amount A elimination of double taxation provisions in Title 5 of the Progress Report on Amount A of Pillar One apply to prevent a multinational group being taxed twice on profits allocated to a market jurisdiction where there is already some form or physical establishment that is subject to tax.
Analysis of South Korea’s Draft Pillar Two Law
On July 22, 2022, South Korea released a draft law to implement the OECD’s Pillar Two GloBE Rules (the ‘draft law’) in legislative notice 2022-128. Read our analysis.
Analysis of Switzerlands Draft Pillar Two Decree
On August 17, 2022, the Swiss Federal Council issued a draft decree for the implementation of Pillar Two of the OECDs Two Pillar Solution from January 1, 2024. Read our detailed analysis.
