| Expectation |
Reality |
Key Lesson |
| “Safe harbours mean we do not have to do much.” |
Safe harbours can materially reduce the need for full GloBE calculations in qualifying jurisdictions, but they do not eliminate the compliance process. Groups must still confirm eligibility, validate the underlying source data, make the relevant elections, retain supporting documentation, and meet applicable GIR, notification and local return requirements. |
Treat eligibility for safe harbours as a simplified compliance pathway, not an exemption from BEPS Pillar Two. Eligibility should be tested and documented jurisdiction by jurisdiction. |
| “Head office will manage BEPS Pillar Two for the whole group.” |
While many groups have adopted a centralised approach, local teams have often played an important role in supporting reporting, notifications and jurisdiction-specific requirements. |
Adopt a centrally governed but locally supported operating model, with clearly defined responsibilities between global, regional and jurisdictional teams. |
| “If we’re not paying top-up tax, BEPS Pillar Two doesn’t really apply to us.” |
Many organisations found that registrations, notifications, and other local self-assessment returns obligations still existed even where no top-up tax was ultimately payable. |
Pillar Two is ultimately a compliance reporting framework. A nil top-up tax outcome does not necessarily mean that no return or notification is required. |
| “Our existing tax technology will handle the requirements.” |
The first round of filings highlighted the importance of understanding whether existing systems could support GloBE calculations, reporting workflows and filing requirements. The challenge often extends beyond the calculation engine. Data had to be extracted from multiple systems, transformed, validated, reconciled and converted into GIR XML and jurisdiction-specific filing formats. |
Organisations need to assess whether their current processes and systems are fit for purpose under BEPS Pillar Two. |
| “We can wait until filing season before focusing on BEPS Pillar Two.” |
Many organisations discovered that gathering the required financial, tax, and entity-level information took longer than expected and often involved multiple stakeholders across the business. |
Begin data collection, obligation scoping and technical analysis well before the deadline to account for reviews, approvals, and validation issues. |
| “The rules are broadly the same everywhere.” |
The OECD framework provides a common foundation, but domestic implementation varies. Differences can arise in legislation, filing dates, registrations, forms, payment requirements, data fields, portal processes, and the treatment of domestic minimum taxes.
Local rules may also require information that is not expressly needed for the OECD calculation.
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Organisations need to understand both the global framework and local jurisdictional requirements.
|
| “This is primarily a tax team responsibility.” |
Tax teams generally lead the technical analysis, but the reporting process depends on information and decisions from finance, statutory reporting, consolidation, IT, data management, legal, treasury and local teams. |
BEPS Pillar Two reporting is often supported by multiple functions across the organisation. Technology specialists and data owners are most effective when involved from the beginning. |
| “Our statutory accounts contain everything we need.” |
Statutory accounts are an important starting point, but they rarely contain all information in the form required for BEPS Pillar Two.
Additional adjustments, entity classifications, deferred-tax information, ownership data, elections, CbCR information and reconciliations may be needed. Source data may also require modification before it qualifies for safe-harbour or GIR purposes.
|
Statutory reporting information remains important, but additional identification of data gaps, transformations and reconciliation controls is needed for BEPS Pillar Two purposes. |
| “Once the first-year filing is complete, the process can simply be repeated.” |
The first cycle created useful templates and experience, but the compliance framework continues to evolve. Changes to safe harbours, UTPR application, domestic legislation, XML requirements, forms and filing systems may alter both the calculations and the information required in later years. |
Convert the first-year project into a sustainable annual operating model, with controlled roll-forward procedures, documented positions and ongoing monitoring of OECD and jurisdictional developments. |
