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BEPS Pillar Two timeline

Indicative timeline assuming legislation first applies to 2024

2023

  • Legislation to be introduced in 2023 to implement Pillar II
  • Forecasts of 2024 Pillar II top-up likely required late 2023

2024

  • First year to which Income Inclusion Rule (IIR) (and QDMTT if relevant) are expected to apply
  • Group tax provisions likely require Pillar II estimate of top-up for 2024
  • Forecast of 2025 Pillar II top-up likely required late 2024

2025

  • First year to which Undertaxed Payments rule (UTPR) is expected to apply

2026

  • First Pillar II tax filing and payment due for 2024
  • Annual domestic information return/overseas return notification (within same due dates as for top-up tax above)

BAU

  • Pay top-up tax for 2025 by 31 March 2027 etc
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