BEPS Pillar Two is coming

With more than 140 countries signing up to Pillar Two under the OECD Inclusive Framework on Base Erosion Profit Shifting (BEPS), a global minimum Effective Tax Rate subjecting multinational enterprises with consolidated global revenue over €750M to an effective tax rate of 15% from 2024, implementation and legislation is gathering pace around the world. Multinational enterprises (MNE) should look to stay on top of these developments and prepare for the transition now in order to ensure readiness for the administrative, compliance and tax impacts under these new rules. The overall impact on tax teams can be significant with well over a hundred overlapping data points to determine Pillar Two top up tax (or qualified domestic minimum top-up tax (QDMTT)) and GloBE tax liability.

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BEPS Pillar Two timeline

Indicative timeline assuming legislation first applies to 2024


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


  • First year to which 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


  • First year to which UTPR is expected to apply


  • 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)


  • Pay top-up tax for 2025 by 31 March 2027 etc
Challenges for tax teams when addressing Pillar Two
As one of the world’s leading global tax content and technology business, our expert team have assessed the challenges and implications to organisations under the Pillar Two regime and the below summarises how CCH Integrator is best placed to assist the transition and future management of Pillar Two.
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In April 2023, in-house tax technology specialists hosted a 30-minute webinar where they shared an overview of the current OECD ruling, discussed the new ruling implications, and how our global tax provisioning software, like CCH Integrator, can address these.

Why CCH Integrator?

  • Integrator is a complete Corporate Tax Performance Management Platform
  • CCH Integrator will guide MNEs through the entire data capture, calculation and reporting requirements of Pillar Two
  • CCH Integrator can interconnect your tax provisioning and CbCR workflow with Pillar Two
  • Provides a single source of truth for data needed for different tax types and allows data to be captured once and used across multiple tax processes

CCH Integrator provides a single platform solution for the office of tax. A corporate tax management platform that interconnects tax provisioning, to CbCR processes with Pillar Two, to filing with the local authority. Built on proven logic, using low code and no code technology, our solution will allow any MNE to easily and efficiently monitor and manage their Pillar Two in-house. Our solution is agile and has been designed in a way that is easily adaptable for local domestic Pillar Two requirements as and when they are required.  Not every Pillar Two provider can do this due to their technology coding limitations and lack of deep tax specialism.

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The CCH IntelliConnect BEPS Resource Centre provides daily news, detailed coverage of developing trends, in-depth analysis, primary source material, plus tools and practice aids to help you navigate the complexities of BEPS.

Updated in real time, you’ll always have the latest information when you need it.

Data integration and data collection

CCH Integrator is ERP agnostic and data can be captured from multiple sources.

CCH Integrator offers standard data upload formats as well as the ability to create any number of file formats to suit your data sources.

The data then populates into standardised schedules through easily maintained mapping templates.

What’s more, as a unified platform across your tax compliance requirements, you can capture your data once and use it many times for the different tax computations required.

With a single source of truth saved in one place, you can have more confidence in your data integrity and reduce the need for dual processes for data input.

Workflow and tax calculations

The CCH Integrator BEPS Pillar Two module will be configured according to the global OECD model while also catering for local legislative requirements.

Maintain control for precise CbC and BEPS Pillar Two reporting by automatically allocating tax structures and jurisdictional rules using the CCH Integrator reporting templates.

CCH Integrator’s flexible design ethos means that even though the Pillar Two rules are being introduced into different domestic legislation requirements and at different timeframes, we are able to continually adapt and configure to meet these evolving requirements.

CCH Integrator Pillar Two calculations work on the basis of data and calculations being created for individual entities, with calculation results being reviewed on a jurisdictional basis.

Reporting, analytics, and visualization

All schedules within the CCH Integrator BEPS Pillar Two module can be extracted as a standalone report. CCH Integrators flexible and intuitive reporting module also allows users to create broader reports with multiple schedules and data reports included.

As the local rules and filing requirements continue to evolve, we will be including the required tax forms and lodgement capabilities.

CCH Integrator Analytics can be utilised to provide analytics oversight for the global calculations of MNCs. Data can be extracted out of calculations in structured and unstructured format to allow for reporting and analytics in external tools.

CCH Integrator is used by all of the Big 4 globally.

Streamline collaboration with your advisor by using CCH Integrator.

As CCH Integrator is 100% cloud, this means that every team member, no matter when they are based, will be working with the most update to data and templates.

Speak to us

We are currently speaking with businesses about their BEPS Pillar Two roadmap, the jurisdictions that they may need to look at, and which technology will best fit their reporting needs.

Our team of in-house tax technology specialists who are ex-Big 4 and global banking, with extensive in-house corporate tax experience would be happy to speak with you.
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