Abstract:

The OECD’s Pillar Two framework aims to ensure multi-national enterprises (MNEs) with annual consolidated revenues of at least €750 million, in at least two out of the prior 4 accounting periods, pay a minimum tax rate on income within each jurisdiction in which they operate. Commonly referred to as BEPS 2.0, the framework imposes a Top-Up Tax on profits arising in jurisdictions where the effective tax rate (ETR) is below 15%. Irrespective of whether any top-up tax ends up payable, the compliance burden for affected organisations will be significant.