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Global Minimum Tax (Pillar Two) in the Central European region

Pillar Two, also known as the Global Anti-Base Erosion (GloBE) proposal, is a significant development in international tax reform. The new framework aims to level the tax playing field by discouraging countries from reducing their corporate income tax to attract foreign business investment. 

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Essentially, it introduces a global minimum tax rate (15%) to encourage multinational enterprises to pay their fair share of taxes. Pillar Two aims to drive these tax outcomes by impacting the financial accounting policies and processes in place at these companies.

Naturally, Pillar Two introduces significant complexity and uncertainty into the economic environment. This is poised to disrupt business operations extensively. The new rules are expected to materially influence corporate strategies, especially in areas such as restructuring, M&A, site selection, and other key operational and investment decisions. As countries around the world work toward implementing Pillar Two, it is crucial that businesses understand its implications and adapt their strategies accordingly.

How to approach compliance for tax and financial reporting purposes?

 

 

Our services

Tax advisory services

Analyses on the application and interpretation of the technical rules, Identifying saving opportunities

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Revision

Preparing or reviewing calculations made for provisioning or tax compliance purposes

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Analyses

Transitional CbCR Safe Harbour analyses

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Assistance & Learning

Assistance regarding deferred taxes and facilitating workshops, educating clients

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Current status of Pillar II in Europe

In recent months, many states have made legislative changes related to implementing the Pillar II regulation. A brief overview of the most important updates is provided below.

Global Pillar Two Legislative Tracker

Tax departments stay informed about Pillar Two measures. Deloitte’s Global Pillar Two Legislative Tracker provides a high-level summary of Pillar Two proposals and enacted laws by jurisdiction. It also offers country-by-country comparisons for easy review.

Contacts by countries

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Our competitive advantage

  • Highly skilled Pillar Two expert team of approx. 10 managers, senior managers, directors and partners.
  • Experience with complex Pillar Two structuring projects, coordination of Pillar Two matters across various jurisdictions and the management of large-scale Pillar Two compliance tasks (regarding Hungarian registration).
  • Availability to provide best-practices and technical support to local tax teams where additional resources or expertise is needed.