Změny pravidel Pilíře 2 jsou tu

Significant negotiations have been taking place on the OECD platform regarding the changes of the Pillar 2 rules. Today, these changes have been published.

What are the main parameters of these changes according to our initial observations:

• Extension of the validity of the existing CbCR safe harbor by one year.
• Introduction of a new safe harbor based on a simplified effective tax rate starting in 2027 (potentially as early as 2026 under certain circumstances).
• Generally, starting in 2026, a more favorable regime for certain types of investment incentives compared to the current rules (up to a certain limit).
• Generally, starting in 2026, the introduction of a so-called side-by-side system primarily aimed at the relationship between the U.S. tax system (and possibly the tax systems of other qualifying countries) and the Pillar 2 rules in the form of simplifications for groups with UPE from these qualifying countries through IIR and/or UTPR safe harbors (generally does not affect the QDMTT rule).

We will provide more details in our January tax and legal reports.

Author:

Karel Hronek