How a multinational organisation prepared for Pillar 2 in less than six months

Although the organisation had well-established tax processes across individual countries, Pillar 2 changed the equation. It introduced a new layer of reporting. The organisation now needed to prepare a group-wide filing, alongside local submissions, all based on consistent information. Each with its own deadline, format and regulatory requirements. A mistake could create inconsistencies across different jurisdictions, potentially exposing the business to additional taxes, financial penalties, and reputational damage.

For this client, the complexity was compounded by the starting point. They had never performed a group-level ETR calculation to determine whether profits in each jurisdiction have been taxed at the required 15% minimum rate. They were not aware of their potential top-up tax exposure. A preliminary analysis revealed a potential substantial liability, which needed to be understood, documented and, to the extent possible, mitigated through valid elections that are foreseen by the rules.

Missing the 30 June 2026 deadline would trigger potential penalties and scrutiny across different jurisdictions. They needed to go from not knowing they were in scope, to being globally compliant across 22 jurisdictions in less than 6 months.

The first priority was scope and structure: identifying which entities were impacted by Pillar 2, confirming the different reporting obligations, and establishing a Global Pillar 2 Steering Committee with the client's CFO, Group Tax Director, and regional tax leads. 

A centralised shared portal gave every stakeholder real-time visibility over data, filings, and compliance status across all 22 countries. We then activated PwC's Global Tax Network, assigning dedicated Pillar 2 experts in each market. These are professionals who understand the local rules and filing obligations.

The most technically demanding phase included calculating the ETR for each jurisdiction under the Pillar 2 rules. This required gathering and analysing data from various sources and jurisdictions and validating the correctness of the computations as per locally applicable rules.

Filing execution ran across the following months and was coordinated through a dedicated technology, PwC’s Pillar 2 Engine. Group and local country filings were generated from a single technology, so the same underlying numbers appeared consistently and with filing support by local PwC experts. The entire process involved over 50 experts in tax, accounting, and business transformation. 

For the first time, stakeholders had a real-time and centralised view of reporting progress across the group. The fragmented set of local processes gradually evolved into one coordinated global approach. 

On 15 June 2026, 15 days before the central deadline, the coordinated filings began. By 30 June 2026, every submission had been made.

The client's GloBE Information Return was accepted by the Luxembourg authorities. All local filings were submitted to their respective administrations on time. Reporting obligations across all in-scope jurisdictions were met with consistent supporting data.

A company that had entered 2026 unaware of its Pillar 2 exposure closed the year fully compliant across every jurisdiction, and with audit-defensible documentation in place for every calculation.

This project also built something more durable than a single year's compliance. The organisation had a clearer understanding of its global tax position; it strengthened the collaboration between headquarters and regional teams, and it created a repeatable framework for other reporting cycles, such as country-by-country reporting. 

The CFO now had a clear, documented position. What began as an unexpected discovery at a tax conference ultimately became a modernisation of the company's tax and accounting governance on a global scale.