Following the OECD's BEPS initiative (Base Erosion and Profit Shifting), the successor project BEPS 2.0 is now also on the home straight. The measures for the redistribution of taxation rights are found in Pillar 1 and have been adopted since 2021. This affects multinational corporations with an annual turnover of more than 20 billion euros - a comparatively small group. 

The situation is different with Pillar 2. The subject here is the introduction of a global minimum tax. At the end of 2021, the OECD states agreed to the plan to subject companies with a consolidated group turnover of 750 million euros or more to an internationally valid minimum tax.

Following the resolution of the BEPS measures, the states are now called upon to create legal foundations. The European Union is also currently discussing implementation (as of June 2022). Although the EU directive has not yet been adopted, it is foreseeable that the announced measures will require intensive preparations on the part of companies. Therefore, companies should already act now and create corresponding processes and structures.

What is in store for multinationals with Pillar 2?

According to the plans of the OECD and the EU, companies with a consolidated group turnover of 750 million euros or more are to be obliged to determine a so-called Effective Tax Rate (ETR). If this is below 15 per cent, a "top-up tax" must be paid. It should be noted that the ETR can be below 15 per cent even if the tax rate in the respective country is above this limit. Irrespective of taxation, international companies are also subject to comprehensive documentation and declaration obligations.

One challenge lies in the availability and procurement of data. Much of the data relevant to the new regime is not captured in other documentation such as country-by-country reporting or trade balance sheets. New processes and comprehensive adjustments to the information from group accounting are necessary in order to collect it efficiently. All of a company's national subsidiaries must be taken into account. This can only be achieved in close, international cooperation between the tax and accounting departments. Practice shows that especially globally active companies from the SME sector have a lot of catching up to do and have to develop the structures first. Time is short, which is why implementation should be initiated immediately.

The global minimum taxation is expected to come into force in the EU states from 2024.

Unser Projektansatz

KPMG has developed a project approach that takes into account the company-specific tax, accounting and IT landscape.

When developing an individual BEPS 2.0 strategy, we proceed as follows:

  1. Examination of the relevance of Pillar 1 and Pillar 2 for your company, taking into account the company-specific characteristics,
  2. Impact analysis and initial risk assessment using various (high-level) simulation and modelling tools,
  3. Analysis of the impact of the new compliance, reporting and payment obligations,
  4. Identification of necessary system adjustments and support in the implementation - by means of an own KPMG solution or the adjustment of your existing tax reporting environment.

Projects in the BEPS 2.0 environment usually require individual solutions, because every company is different. Our team of experts from the areas of accounting, IT and international tax approaches the projects in an interdisciplinary manner and always keeps the requirements of the audit in mind. By developing our own technology and collaborating with renowned software providers, we support your project with innovative solutions. In doing so, we dock onto your existing infrastructure, so that extensive reconstruction of the existing IT system is usually not necessary. You also benefit from our international network. We work closely with this network to meet the requirements of the countries relevant to you. 

You can find more information here:

We support you in the development of your BEPS strategy. Get in touch with us.

Your contacts