The Global Minimum Tax of Pillar II

On october 8, 2021, within the OECD/G20 Inclusive Framework (which now includes 147 member States), an agreement was reached among participating countries as part of the reform of the international tax system. This agreement introduced a two Pillar solution to address the tax challenges arising from the digitalization of the economy. Pillar II was specifically designed to ensure that multinational enterprises (MNEs) pay a minimum level of tax on the profits they generate globally. To this end, with the publication of the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy and the subsequent development of the Global Anti-Base Erosion Model Rules (GloBE), a global minimum tax (GMT) of 15% was established. This minimum tax applies in each country where a multinational operates, provided that the country has joined the OECD BEPS Pillar 2 framework.

The Global Minimum Tax (GMT) aims to establish a minimum level of taxation for domestic and multinational groups (including those with either a parent company or even just a subsidiary located in an EU member state) that have a total consolidated revenue of at least € 750 million, generated in at least two of the four fiscal years immediately preceding the relevant year. This applies regardless of the EU member state where the revenues a...