BEPS 2.0 Pillar Two


How much time, resources and investment will it take enterprises to comply and country tax authorities to administer? Marna Ricker, EY Global Vice-Chair for Tax, highlights the key points.

Being prepared for global minimum taxes

MNEs need to keep a close eye on developments in relevant jurisdictions as they implement global minimum tax rules into their domestic laws. Most large organizations are only at the start of their global minimum tax journey. Organizations will need to find ways to  calculate their new taxes, evaluate the impact on their financial statements, and report to the relevant tax authorities around the world. They will also need to adapt their internal processes and systems to manage the new computations and data, to calculate their global minimum tax liabilities and satisfy reporting obligations.

Government tax policymakers around the world are collaborating on proposals for significant changes to international tax rules in light of the globalization and digitalization of the economy. The G20/OECD project on addressing the taxation of digital economy began in 2019, building on the final reports issued in 2015 in the earlier project on BEPS.

The current project, referred to as BEPS 2.0, has two elements:

  • Pillar One on new nexus and profit allocation rules with the objective of assigning a greater share of taxing rights over global business income to market countries, and
  • Pillar Two rules on new global minimum tax, approved in December 2021 by 141 jurisdictions participating in the BEPS 2.0 project.

The Pillar Two Model Rules provide for a global minimum tax of 15% applicable to multinational enterprise (MNE) groups with a global turnover of €750 million or more. 

What EY can do for you

EY’s integrated global team of local and international tax, tax compliance, and tax technology professionals can help you navigate the complex rules and assess potential impacts. EY teams can also work with you to develop a robust, actionable plan to be ready when the rules are enacted and effective.

End-to-end support for a major tax challenge

Businesses affected by Pillar Two may have already started to assess the impact on their future effective tax rates (ETR), but this is just the beginning. Here is a snapshot of the four steps in the path toward managing global minimum taxes – most organizations are only at step one. 

Transfer pricing certainty in uncertain times

Our new survey finds that businesses are prioritizing transfer pricing certainty in an era of global minimum taxes.

Tracking the latest BEPS developments

The EY BEPS tracker helps you monitor latest developments in jurisdictions related to the implementation of global minimum tax rules.

Developing a bespoke action plan

Once a multinational organization conducts a  high-level  impact assessment, an actionable plan for global minimum taxes in terms of compliance and management will need to be established. But as the clock is ticking, any challenges should be diagnosed as early as possible, so that they can be resolved before implementation.

Implementing the plan

Being prepared for Pillar Two will require significant cross-functional coordination involving tax, accounting, legal, systems/IT, and business stakeholders.

The complexity around global minimum tax rules can be an overwhelming proposition for some, and a major challenge for all. By working with EY teams, your organization can manage this complexity and be compliant with applicable rules, balancing cost, service, tax controversy, and tax risk.

The Latest on BEPS and Beyond

Read EY's monthly report with brief summaries of the latest activity in the OECD BEPS project and more.


Pillar Two and the role of business applications

EY knowledge meets ecosystem partner technology. Explore how the EY and SAP alliance helps corporations respond to the challenge.

BEPS 2.0: New OECD releases and ongoing implementation activity

In this 90-minute EY Global webcast, the panelists examine the latest OECD releases on both Pillars and explore the growing legislative activity as jurisdictions begin to incorporate global minimum tax rules into their domestic law.


The team

Jeffrey Michalak

EY Global International Tax and Transaction Services Leader

Passionate about providing exceptional client service. Dedicated to developing and mentoring people to help them achieve their highest potential.

Detroit, USA

Barbara Angus

EY Global Tax Policy Leader

Enthusiastic participant in the global tax policy dialogue. Zealous advocate. Leverages invaluable experience gained as a founding member of an all-lawyer comedy troupe.

Washington, DC, USA

Daniel Gentsch

EY Global International Tax and Transaction Services (ITTS) Deputy Leader

Supports tax departments in transformation.

Zurich, CHE

Ben Smith

EY Global Deputy Compliance and Reporting Leader

Leading engagements across borders. Focused on efficiency and new ways of working. Champion of EY Global Delivery Services. Sponsor of our homegrown talent. Cricket fan. Father of three boys.

London, GBR

Albert Lee

EY Global Tax Technology and Transformation Leader and EY Asia-Pacific Tax Technology and Transformation Leader

Technology leader in the world of tax. Passionate about innovation.

Hong Kong SAR, CHN

Matt Andrew

EY Asia-Pacific Tax Policy Leader

Experienced in transfer pricing and operating model effectiveness matters. Frequent lecturer. Family man. Lifelong lover of learning.

Auckland, NZL

Jose Bustos

EY International Tax Services Policy Desk Leader

Passionate about international tax and tax policy. Helps organizations navigate the latest international tax policy developments.

New York, USA

Marlies De Ruiter

EY Netherlands International Tax Services Partner, Global International Tax & Transaction Services Policy Leader

Dedicated to helping organizations navigate the latest international tax policy developments. Passionate about bringing people together and jointly creating better alternatives.

Rotterdam, NLD

Brian Foley

EY Global Tax Accounting and Risk Advisory Services Leader

Passionate about creating value in and through tax accounting. Drummer who is always looking for a gig. Husband and father.

Dallas, USA

EY webcasts

View a list of all upcoming EY webcasts (including those on BEPS 2.0) or access on-demand replays of our past webcasts.

BEPS 2.0 Tax Alerts

Keep up-to-date on significant BEPS 2.0 developments by signing up to the EY global Tax Alerts library (select “BEPS 2.0”)

Subscribe for webcast updates

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Our latest thinking

How Microsoft Power Platform can help address new BEPS 2.0 requirements

In this webcast, panelists discuss the minimum taxes data and technology challenge and the role of Microsoft technologies. Learn more.

29 May 2023 | 11:30 your local time

How economic, geopolitical and technological ripples impact the tax agenda

In this webcast, panelists discuss how markets and countries will ride out the economic, geopolitical and technological disruption. Learn more.

08 Sep 2022 | 17:30 your local time

Why five years of transforming tax and finance functions is paying off

New tax operating models in the last five years delivered value to businesses, EY survey shows. The next five years will add even more. Read more.

20 Jun 2023 EY Global

How tax accounting teams should prepare for BEPS changes

Why tax accounting teams need to prepare for the implementation of BEPS, and how the obstacles may vary from country to country. Learn more.

28 Apr 2023 Brian Foley

Five steps tax accounting teams can take for BEPS 2.0 

With BEPS 2.0 due to come into force in late 2023/early 2024, tax accounting teams prepare for Pillar Two rules on global minimum taxation. Learn more.

21 Mar 2023 Adam Sweet

How a global minimum tax will affect sustainability tax incentives

Multinationals and jurisdictions may need to rethink their sustainability tax incentives if countries adopt 15% global minimum tax rules. Learn more.

27 Feb 2023 EY Global

Why BEPS 2.0 needs consistency, coordination and certainty

The G20 must lead – and consider input from businesses – to make tax transformation workable for all. Learn more.

23 Jan 2023 Barbara Angus

    Watch latest webcasts on BEPS

    How to address the BEPS 2.0 Pillar Two data and technology challenge

    In this webcast, panelists discuss the minimum taxes data and technology challenge and the role of SAP business applications. Learn more.

    13 Mar 2023 | 13:00 your local time

    Implementation of BEPS 2.0 Pillar Two in the European Union

    In this webcast, panelists discuss implementation of the EU Minimum Tax Directive and potential implications for impacted businesses.

    26 Jan 2023 | 13:00 your local time

    BEPS 2.0 developments: What to watch out for in country implementation

    In this webcast, panelists discuss the dynamics of the BEPS 2.0 project, as well as the status and outlook for Pillars One and Two. Learn more.

    15 Sep 2022 | 14:00 your local time

    Evolution of tax in the European Union

    In this webcast, panelists discuss the changing EU tax policy landscape and potential implications for businesses.

    06 Jul 2022 | 13:00 your local time

    What companies should know about the latest BEPS 2.0 dynamics

    In this webcast, panelists discuss the evolution of Pillars One and Two. Learn more.

    12 May 2022 | 14:00 your local time

    BEPS 2.0: Implications of Pillar Two for businesses

    In this webcast, panelists discuss BEPS 2.0 developments. Learn more.

    22 Mar 2022 | 18:00 your local time

    BEPS 2.0: Focus on Pillar Two

    In this webcast, panelists discuss the latest developments on global minimum tax rules under Pillar Two of the OECD/G20 BEPS 2.0 project. Learn more.

    14 Jan 2022 | 16:30 your local time
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