Our solution for GloBE and Pillar 2

The GloBE regulations of the Base Erosion and Profit Shifting (BEPS) project of the OECD and the G20 countries are intended to make aggressive tax structuring schemes unattractive by introducing regulations that stipulate a global minimum tax of 15% for multinational enterprise groups with a minimum revenue of € 750 million annually.

With the Safe Harbour rules, the OECD has now given many companies an easier way to implement the GloBE rules of Pillar 2. The temporary Safe Harbour rules shall apply to all fiscal years beginning before or on 31 December 2026 and ending no later than 30 June 2028. They are designed to significantly reduce the compliance and administrative burden for companies and greatly simplify the calculation and preparation of tax returns.

Our approach

We collaborate with you to analyse GloBE’s impact on your company, explore how the Safe Harbour rules can be applied to your benefit, identify all the necessary data (taking into account your company’s specific characteristics), and provide you with a detailed action plan with recommendations. In addition, we identify other considerations important to your company’s future, such as developing new data consolidation processes, adapting your ERP systems and/or consolidation tools, and ongoing monitoring of your Pillar 2 reporting obligations and their impact.

Our solution

We offer you a pragmatic, holistic solution: to collect and analyse your data, we construct the Mazars Pillar 2 tool on your existing internal systems or, if desired, integrate our process structure directly into your system landscape.

Implementation of our measures takes place in four phases.

• Phase 1: We create a complete, detailed overview of all business units and their (minimum) tax treatment in Mazars' Pillar 2 tool.
• Phase 2: We supplement the data in our Pillar 2 tool by providing the additional information necessary for the GloBE calculations.
• Phase 3: We identify the business units that qualify for the temporary Safe Harbour rules. Next, we use the tool to prepare an interim report that gives an initial robust overview of the impact that Pillar 2 will have on your business.
• Phase 4: The results from the previous phases of the Pillar 2 project are taken into account and, if necessary, we also conduct a comprehensive GloBE calculation. This gives you a precise and timely overview of the necessary additional tax accruals. Due to the international focus of Pillar 2 projects, our consulting always takes a global approach.

How you benefit

We offer you a solution carefully designed to fit your needs, a quick identification of the actions needed, and transparency regarding your compliance with the GloBE regulations. In our tool-supported approach, we guide your company through the first phase of scoping and the temporary Safe Harbour rules, provide you with specific recommendations for action, and prepare you for the further phases of Pillar 2. Our interdisciplinary teams work closely with each other and with you to develop a pragmatic plan specifically tailored to your company.

Would you like to learn more?

Contact us