BEPS Pillar Two - Expert recommendations for implementing global minimum taxation in corporate groups

With the Base Erosion Profit Shifting (BEPS) tax reform, the OECD is addressing the challenges of an

increasingly globalized and digitalized economy.

Preceding BEPS, international tax law has led to glaring tax inequities. To prevent this, BEPS Pillar Two

presents a global minimum taxation for multinational enterprises (MNEs) of 15 percent, which is to be ensured

by a “top-up tax,” when necessary.

While adhering to BEPS sounds relatively straightforward, it harbors a high degree of

implementation complexity.

This white paper summarizes the most important aspects of BEPS Pillar Two and offers concrete

recommendations for selecting suitable BEPS Pillar Two solutions and service providers.