Pillar Two services

You should undertake an impact assessment to determine high-risk areas and identify the potential impact on compliance requirements and cash tax. We can ensure your assessment is comprehensive and delivers a full picture.

We can assist with safe harbour reviews, including the transitional CbCR safe harbour. We will establish whether a CbCR report constitutes a qualifying CbCR report for the purposes of a particular territory. We can support in remediating the CbC process where required. 

We can support with modelling ETR and cash tax impact. We can help you build a model, or use our own, under both the OECD Model Rules and local implementation rules. We can also support you in engaging and communicating with your senior stakeholders in respect of the impact of Pillar Two.

You can rely on us to address specific accounting complexities and provide assurance over work already undertaken. 

The right corporate structure and optimised legal and operating models will reduce the risk of double taxation and will support effective and efficient compliance and reporting. We will help identify and implement legal and operational restructuring opportunities to address cash tax impact or to ease compliance burden.

We can identify any Pillar Two issues related to transactions, restructurings and reorganisations including the potential impact on the application of safe harbours as well as potential top-up tax liabilities and the identification of tax attributes to be assessed and tracked into future periods.

You can get support for your stakeholder management and communications with your Board and other stakeholders. You will be kept up to date with any relevant local implementation and/or interpretations of Pillar Two rules. 

We can help you design and implement a roadmap for Pillar Two compliance. You will get support in meeting registration obligations around the world and in preparing and filing of your Global Information Return (GIR) and other Pillar Two related returns and notifications in relevant jurisdictions. 

You should consider the governance, processes, controls and data gathering for Pillar Two readiness and compliance. You can choose to what extent you want us involved and responsible for your Pillar Two compliance from a fully outsourced solution to a co-sourcing approach or we can review and provide assurance over your existing governance.

Where you choose an in-house or co-sourced approach, we can provide the tools and data collection packs to support your internal processes. We can also support you in the identification, assessment and implementation of an appropriate technology solution. 

You can delegate preparation of quarterly safe harbour and Pillar Two computations based on full year forecasting for use in financial statement reporting and wider business planning. 

We provide appropriate and cost-effective education or training to tax teams, accounting teams and other stakeholders. 

Tax functions have usually turned to spreadsheet models or data analytics tools to undertake specific tax analysis. Pillar Two is too large, too broad and too complex to rely on those traditional tools. The rules continue to evolve, and local requirements vary enormously.

There is a burgeoning third party technology market developing with a significant number of vendors offering a range of solutions aimed at different parts of the market. Our Pillar Two tax technical and tax technology specialists are truly independent of any single software solution. We will simply help you identify the right technology solutions to support your compliance and reporting.

As a full-service firm, we help with the vendor selection, and we provide full implementation and support services. As approved implementation partners for all vendors, we offer a unique perspective.