Pillar Two: 122 Data Points for Systems Implementation

For MNES looking at an effective systems implementation to accurately calculate any Pillar Two top-up tax and allocate this to the required group entities, a tax data mapping assessment is the first step (for an analysis of why this is important, see Why Tax Data Mapping for Pillar Two is Crucial).

This takes the required data points required to apply the Pillar Two rules and allows the MNE to match these either with existing data sources (eg in the ERP or EPM system) or create new data sources to specifically pull the required Pillar Two data. In practice, a number of the data points for Pillar Two will already be in place for other international tax reporting requirements (eg CbC reporting).
The Pillar Two data points are therefore the lynchpin of an effective strategy to implement systems changes to apply Pillar Two.
Given the OECD Administrative Guidance also confirms that an MNE should be able to use the same data points for calculating its qualified domestic minimum top-up tax liability (QDMTT) that it uses for calculating its GloBE tax liability, these data points will also be relevant for the QDMTT calculation.
We include below the key 122 data points that all MNEs will need to undertake a tax data mapping exercise for Pillar Two.