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Pillar Two
Meeting data and compliance requirements
The Minimum Tax Act, also known as Pillar Two, sets a minimum effective tax rate of fifteen per cent per jurisdiction. Companies with a global turnover exceeding 750 million euros fall within the scope of Pillar Two. Where the effective tax rate (ETR) in a jurisdiction is below the minimum of fifteen per cent, a top-up tax may be applied up to the minimum rate.
What you need to know to be compliant
Webcast: Pillar 2 update (in Dutch) - 7 April 2026
In this third webcast, we take a deeper look at what you need to know to be compliant with Pillar Two. We examine, for example, how you can deal with Country-by-Country reporting (CbCr).
What you need to know about permanent safe harbour rules and the side-by-side approach
Webcast Pillar Two: update 7 January 2026
The OECD has issued guidance on permanent safe harbour provisions and the interaction between Pillar Two and the US NCTI rules (formerly GILTI). This is a step towards simplification within global tax frameworks. During this webcast, our experts explore what these changes mean for multinationals: whether it concerns US groups operating in EMEA or EMEA-based organisations that fall within the scope of Pillar Two. We share practical insights on compliance, data readiness and strategic planning.
What you need to know about the latest developments
Webcast Pillar Two: update 7 October 2025
Given the geopolitical influences and the changes and tightening from the OECD, in this webcast we provide you with an update and practical guidance. What do you need to do at a minimum to be compliant?
How PwC can help you with Pillar Two
The implementation of Pillar Two brings complex challenges. The global minimum tax requires you to adapt your systems, technology, processes, governance and controls to evolving data and compliance requirements. Get this right, and you create opportunities for growth.
We can help you to collect and transform the necessary data, calculate the impact of Pillar Two and meet your compliance obligations. To do so, we use a technology-driven end-to-end approach, with our Sightline platform and our Pillar Two Engine. Together with our global network of international tax specialists, we make the complexity manageable.
Data strategy in order
One of the first steps taxpayers must take for Pillar Two is identifying the data requirements and developing a data strategy. Collecting and consolidating data is an enormous challenge, as the data must come from many different sources under the responsibility of various stakeholders.
Early, integrated collaboration is crucial so that data and system owners are aware of the data requested under Pillar Two, its importance, and the impact of Pillar Two on their work.
PwC's experts help to:
- identify data requirements,
- develop a data strategy that is embedded in systems, and
- design processes that support the reporting and compliance requirements.
PwC's Data Input Catalog
PwC's Data Input Catalog is central to our end-to-end process for Pillar Two. The Data Input Catalog defines the required data for Pillar Two, provides you with full insight into the volume of work needed to comply and helps you to anticipate the unique challenges your business faces. PwC's Data Input Catalog is the starting point for a comprehensive data strategy, offers insight into data availability and helps to determine a modelling approach. The Data Input Catalog gives you the foundation to be ready for Pillar Two.
PwC's Pillar Two Engine
PwC's Pillar Two Engine is a structured model for assessing the impact of Pillar Two. It supports the specific application of Pillar Two rules across the globe and allows for flexibility as those rules evolve.
Various variations and interpretations of local rules require an iterative modelling process for Pillar Two calculations. PwC's Pillar Two Engine works with different data structures and sources and prioritises the most important adjustments and selections. The modelling provides calculations for compliance and for the formation of provisions. It also offers a data visualisation to identify the key areas where there is a risk of a tax charge under Pillar Two.
Our Pillar Two Engine uses a centralised database with a validated calculation that is aligned with PwC Global Tax technical and policy leaders. The database is dynamically updated with rule changes and new legislation in each jurisdiction.
Video
Pillar Two Module in Sightline
1:51
More tools
Transcript
Pillar Two Country Tracker
Discover the status of the implementation of Pillar Two across different countries
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