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Pillar Two Scope Overview

Pillar Two Tracker

Pillar Two - Scope

The scoping rules in Article 1 of the OECD Model Rules determine which MNE groups are subject to the Pillar Two GloBE rules.

Summary of the Approach

The general procedure to determine if a group is in-scope will be:

• Identify if there is a Group
• Identify the Ultimate Parent Entity
• Identify if there is an MNE Group for the purposes of the Pillar Two GloBE Rules
• Look at the consolidated group revenue and see if the revenue threshold test is met.

image showing 'how to determine the scope of the Pillar Two GloBE rules'
Lee Hadnum
Lee Hadnum
Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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