Global BEPS Pillar Two tax compliance software

BEPS Pillar Two is an OECD /G20 Inclusive Framework initiative, representing a once in a generation corporate tax reform that establishes a global minimum effective tax rate of 15% for in-scope multinational enterprises (MNEs). Reporting requirements include the GloBE Information Return (GIR) required under the GloBE model rules. It is used to provide tax authorities with information about an MNE group’s Pillar Two position, including jurisdictional calculations, constituent entities and relevant top-up tax information.

If your organisation is in scope of the Pillar Two rules (by annual revenue threshold EUR 750M+ and jurisdictions adopting the rules), you must be prepared to calculate jurisdictional effective tax rates and any top‑up tax, comply with local registration and payment requirements, and prepare and file a GIR. Many jurisdictions have enacted the GloBE model rules in legislation for fiscal years starting on 1 January 2024, with 30 June 2026 being the earliest mandatory GIR filing deadline.

Achieving confidence by this date requires that data collection, calculation methodologies, governance processes, and reporting capabilities are operational well in advance. Early preparation is essential to mitigate compliance risk, avoid penalties, and manage stakeholder expectations.

An MNE group will fall in scope of BEPS Pillar Two reporting obligations so long as one country which they operate in, has implemented the Pillar Two framework into legislation. This means that MNE groups will still be required to comply with BEPS Pillar Two reporting obligations (including lodgment of GIR and required local top-up tax returns as applicable) even if they are headquartered in a country where BEPS Pillar Two has not been implemented yet.

The OECD GIR XML schema provides a common technical structure for MNE groups to remain compliant, but there may be country-specific requirements that vary by jurisdiction and need to be considered.