BEPS 2.0

BEPS 2.0 rules dramatically change the international tax landscape, potentially bringing reporting and compliance challenges to every industry.

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.

Find out more

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.

Download the pdf

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.

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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.

Read the latest edition

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.

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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.

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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”)

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