Tax & AccountingSeptember 05, 2025

BEPS Pillar Two Requirements for MNEs – Myth vs Reality

BEPS Pillar Two is part of the OECD’s global tax reform initiative aimed at ensuring large multinational enterprises pay a minimum level of tax – regardless of where they operate.

At its core is the Global Minimum Tax, set at 15%, designed to curb profit shifting to low-tax jurisdictions and promote fairer competition across borders.

But as implementation unfolds, confusion and myths abound. We cut through the noise to explore what Pillar Two really requires, separating fact from fiction or myth from reality when it comes to the evolving landscape of international tax. We also explain how our award-winning corporate tax software platform can assist in meeting BEPS Pillar Two compliance obligations.

Myth Reality Recommendation Solution
“I don’t need Pillar Two software because there are safe harbours available.” While safe harbours can simplify compliance and reduce administrative burdens, they do not eliminate all duties/tasks. For example, you still need to lodge a GIR to fulfil your compliance. MNEs should consider how they plan to manage remaining compliance obligations, like lodging the GIR, even if safe harbours are available. CCH Integrator produces compliant GIRs with validations to meet lodgment obligations. It streamlines safe harbour testing, GloBE ETR calculations and jurisdictional management.
“HQ will handle it; I don’t need to worry about Pillar Two.” HQ may lead strategy, but local tax teams are usually responsible for local filing and notification duties. You’re still accountable for local compliance. Regional teams need to consider how to manage local filing and notification duties, especially if HQ delegates these responsibilities. CCH Integrator tracks local obligations and supports “one-in, all-in” filing via filing notifications. With role-based access, CCH Integrator ensures secure and coordinated submissions.
“Pillar Two is only relevant for companies paying top-up tax.” Pillar Two is a reporting framework. Even with zero top-up tax, you will still need to lodge returns and provide lodgment notifications. MNEs need to consider how to manage reporting and lodgment obligations regardless of whether top-up tax is owed. CCH Integrator provides comprehensive calculations and compliance features to cater for your specific requirements.
“Pillar Two is an OECD guideline — it’s optional.” OECD frameworks are adopted by member countries and integrated into their respective legal systems. Once implemented, Pillar Two is a requirement under local law, and non-compliance may result in penalties. For instance, this is now law in Australia. To avoid potential penalties and reputational damage, it’s important to know that BEPS Pillar Two is not optional, and MNEs need to be prepared for the first lodgment deadline(s). CCH Integrator includes updates to reflect changes in local legislation and reporting requirements.
“UPE jurisdiction isn’t enacting BEPS P2, so we don’t need to do anything.” Even if the UPE jurisdiction hasn’t implemented Pillar Two, other jurisdictions—including Australia— have. If your group operates globally, you must comply where rules apply. If your group operates in jurisdictions which have enacted Pillar Two (like Australia) – you will need to start preparing for local compliance obligations. CCH Integrator supports local implementation, currency conversion, and QDMTT/GIR tracking across entities to ensure readiness.
“Our local tax software will handle Pillar Two automatically.” Most legacy systems weren’t built for GloBE logic, XML schema reporting, or safe harbour testing. Test your current system for GloBE logic, XML schema reporting, and safe harbour testing across jurisdictions.

CCH Integrator is purpose-built for Pillar Two.

It includes smart forms, error handling, validation and producing returns compliant with OECD and local standards.

“We only need to prepare for Pillar Two in the year it applies.” Pillar Two often requires prior-year financial and tax data. Waiting risks data gaps and missed deadlines. Ensure you have the prior-year data needed for calculations and filings - if you wait until the year of application it may be too late to do this work in time.

CCH Integrator enables early ERP mapping, gap analysis, and scenario testing.

It supports forecasting and historical data tracking for proactive compliance.

“Safe harbour rules are the same in every jurisdiction.”

OECD sets the framework, but local authorities may add their own criteria.

You might qualify in one country but not another.

Start tracking jurisdiction-specific safe harbour criteria, especially where local rules diverge from OECD guidance.

CCH Integrator adapts to jurisdiction-specific definitions and thresholds.

It tracks QDMTT variations and safe harbour eligibility across entities.

“Only the parent company needs to worry about Pillar Two.” Subsidiaries and branches may have independent filing or payment obligations by law. Local compliance steps still apply. Consider your approach for managing local filing or payment obligations for subsidiaries and branches that may be independently liable. CCH Integrator coordinates central and local compliance. It tracks obligations by role, entity, and jurisdiction with full audit visibility.
“Pillar Two won’t affect our finance team.” It impacts finance, tax, legal, and systems. ERP mapping, accounting policies, and intercompany processes may need updates. Consider how your organisation’s ERP mapping, accounting policies, and intercompany processes might need to change under Pillar Two. CCH Integrator is ERP-agnostic, supports IFRS/local GAAP, support nuanced security access and audit trails for cross-functional collaboration.
“We can use our statutory accounts without adjustments for GloBE.” Statutory accounts alone aren’t enough. Start planning how to handle GloBE-specific adjustments to profit, deferred tax, and inclusions/exclusions that differ from provisioning. CCH Integrator performs GloBE-specific calculations and reconciliations. It handles multiple currencies and accounting standards with built-in logic.
“The OECD will enforce Pillar Two.” Administration is managed by local tax authorities. OECD sets the rules, but penalties and audits are local. Be audit-ready in the event that you need to undergo a local audit. CCH Integrator tracks local filing progress, formats, and audit trail requirements. It supports revised filings and compliance documentation as needed.

BEPS Pillar Two is not optional, the clock is ticking

BEPS Pillar Two marks a major shift in global tax compliance. MNE groups must prepare thoroughly to meet new obligations and avoid penalties.

Learn more about our BEPS Pillar Two software and knowledge solutions or talk to one of our BEPS Pillar Two technology experts today to get started.

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