What is Pillar Two? When does Pillar Two come into effect?
Pillar Two establishes a jurisdictional effective tax rate of at least 15% to multinational groups with consolidated revenue of at least €750 millions. Global agreement has been reached to bring these rules into law and the OECD has released model rules, commentary and administrative guidance. EU member states have unanimously adopted the EU Council Directive 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the European Union, known as the EU Pillar Two Directive or the GloBE (Global anti-Base Erosion). At EU level, the rules had to be implemented by 31 December 2023. Many non-EU countries have also implemented Pillar Two in their domestic rules.
On 20 December 2023, the Luxembourg Parliament voted to approve the Pillar Two law transposing the EU Pillar Two Directive. The law entered into force as from fiscal years starting on or after 31 December 2023. The Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-up Tax (QDMTT) became effective for fiscal years starting on or after 31 December 2023, whereas the Undertaxed Profits Rule (UTPR) became effective for fiscal years starting on or after 31 December 2024. The Luxembourg Pillar Two Law was amended in December 2024 to incorporate the latest administrative guidance issued by the OECD and clarify some important principles which could be relevant for Luxembourg businesses impacted by the rules. Please refer to our newsalert for further details.
Are you #PillarTwoReady?
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How we can help you
As the EU and other countries move toward enacting the Pillar Two, businesses will need to navigate intensive data collection, analysis and compliance. PwC Luxembourg and the PwC network firms provide tailor made solutions to prepare groups for their Pillar Two obligations, including estimating potential top-up tax impact, preparing systems for data gathering and automation, upskilling teams and assisting groups with the Pillar Two compliance process.
Assess
We help assess and model the likely financial and operational consequences of Pillar Two.
Services include:
- Training and upskilling your Group on Pillar Two with a focus on the industry and the special features of your Group
- Scoping exercise addressing the qualification of group entities for Pillar 2 purposes. For fund structures, have a look at our self-assessment test to review whether your fund or corporate structure could be subject to the Pillar Two rules.
- Design a tax reporting process and implementation roadmap for internal group purposes which would identify milestones, deliverables and team allocation
- Discussion on current status of country-by-country reporting and potential application of Transitional Safe Harbours. Is your Country-by-Country Report Qualified?
- PwC Data Input Catalog to identify required data points and whether the required data is already available or how it could be made available going forward
- Modelling to understand both Pillar Two financial and process impact on key jurisdictions and assist in briefing internal stakeholders
- Assessment of whether it may be beneficial to make structural changes
- Stakeholder and financial accounting communications
Report
We can enhance your reporting and data analytics capabilities.
Services include:
- Impact assessment in PwC modelling tool on the basis of first data gathered - repeated as part of an iterative modelling approach based on further data gathering. Check our PwC Pillar 2 Engine
- Assistance with design or review of disclosures in group financial statements
- Consulting on tax accounting treatment
- Validate deferred balances ahead of first Pillar Two reporting period
- Review and assessment of GloBE elections and opportunities
- Definition of (process) adjustments & new processes need to close the gap between your as-is and to-be set up from a group and country perspective.
- Deployment of Target Operating Model and IT solutions
Comply
We help you meet your ongoing reporting and compliance obligations.
Services include:
- Implementation of a Pillar 2 compliance solution aligned with your existing compliance and reporting tools
- Assist with the registration of all Luxembourg constituent entities with the tax administration in Luxembourg, including assessment of designated filing and paying entities
- Assist with the preparation of the Pillar 2 tax declarations, GloBE Information Return and the QDMTT return
- Assist with the preparation and filing of the Pillar 2 notifications.
- Training of staff dealing with the compliance process
- Documentation of Pillar Two related processes and controls to align with tax governance frameworks
Still have some questions without necessarily embarking on the full Pillar Two journey? We are launching a new Pillar 2 service, #Pillar2 Helpline! Our Pillar 2 experts stand ready to discuss any practical or technical matters through a quick call (+352 621 333 228) or via our form.
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