Deloitte OECD Pillar Two Tax Advisory services

We can help you understand the unfolding consequences of OECD tax rules and local country legislation on your business, and help you navigate the complexities of Pillar Two income, covered taxes, compliance, and other considerations for every jurisdiction you operate in.

Compliance with OECD Pillar Two demands detailed calculations involving large amounts of highly granular tax, accounting, and reporting data—likely far more, and more detailed information than you are currently collecting for existing tax reporting. Deloitte's Pillar Two assessment specialists can help you identify the data to be gathered and evaluate the potential impact on your business by modelling scenarios and communicating the analysis with powerful business intelligence and data visualizations. Taking into account your tax profile and global footprint, we can help you estimate tax liability, now and over time, as both Pillar Two rules and your business evolve.

OECD Pillar Two's complex new data reporting requirements include over 150 data points, which must be sourced from multiple systems including, but not limited to, financial systems and sub-systems, tax systems and models, and legal and non-financial systems. Deloitte's Pillar Two specialists have created a data diagnostic tool that they use to gather the data necessary to help you understand what data is needed, where it exists in your systems, and what gaps they may have. Our services can help you identify and capture the specific tax, accounting, and company data required for OECD compliance and help you implement sustainable data collection processes and technology with the potential to transform your tax data strategy.

Multinational corporations have the opportunity to leverage their ERP systems to support increasingly complex Pillar Two reporting requirements which will require specific data elements to be able to provide the proper level of detail to manage complex calculations and integrate with group tax reporting systems. The specifics will depend on the configuration and flexibility of your current system together with reporting deadlines and planned upgrades. Whatever form system enhancements take, Deloitte can help you bridge the gap between reporting requirements and the technology response with end-to-end tools designed to support both current and expected future OECD requirements.

Pillar Two rules raise a number of data and tax technology questions. Do you have access to the data, tools, and processes you need? Pillar Two will not only require enhancements to existing finance and tax systems but will likely require new systems to enable the business to be compliant. Our teams can help analyse what solutions are needed and articulate where and how requirements may need to be built into finance and other system transformations--along with helping you operationalize new calculations and reporting requirements across the business. We can help you analyse your ability to support new data, analysis, and reporting requirements; detect gaps; and design and roadmap a new or expanded architecture that supports both current and projected Pillar Two requirements. With a deep understanding of business processes, our technology professionals can help create end-to-end solutions to meet your needs.

Pillar Two envisages a minimum global tax rate of 15% in the jurisdictions where in-scope multinational enterprises operate. But how its rules are interpreted may vary by jurisdiction. Combining deep country-specific knowledge with a global perspective on tax policy developments, Deloitte’s tax technical advisory specialists can help evaluate the effect of corporate lifecycle events on tax, including the impact of Pillar Two on events ranging from where you put your IP to mergers, acquisitions, divestitures, and reorganizations. Drawing on this deep experience, we can help you interpret both new and evolving rules with an eye toward the future of your business.

Pillar Two dramatically increases the complexity and scope of tax accounting for multinational entities. Under IFRS and US GAAP rules, companies must account for the impact of Pillar Two for both interim and year-end reporting. Critical to this effort will be having the correct legal entity results accounted for and recorded at the appropriate legal entity level so that the correct top-up taxes can be determined. Many companies do not currently account for operating results at the legal entity level in their consolidated financial statements. Deloitte's Accounting & Reporting Advisory and tax provision specialists can help you gather the relevant data, incorporate complex Pillar Two calculations into overall provision computations, and meet rapidly approaching financial statement deadlines.

Completing the new OECD Pillar Two information return represents a global undertaking requiring data points—many of which are complex composites of underlying data. The size and complexity of the data requirements are further complicated by timing: while in many cases the first return is typically filed within three to 12 months following the accounting period end, subsequent returns must be filed in less time—so even before you complete your first return, you will need to make decisions about ongoing compliance and reporting. We can help you complete your Pillar Two filing accurately and timely, from return validation to completing required documentation.