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Pillar Two Essentials - Chih ling Kuo

Pillar Two Essentials

By: Chih ling Kuo

eBook | 6 March 2026

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Are you ready for the biggest corporate tax reform in a century?

The OECD Pillar Two global minimum tax is no longer a proposal — it is live in over 50 countries, and your multinational group may already be in scope. If your consolidated revenue exceeds €750 million, the 15% minimum effective tax rate now applies to you.

OECD Pillar Two Essentials V2.2 is the practical, up-to-date guide written for tax directors, group controllers, CFOs, and international tax advisors who need to understand — and act on — the Global Anti-Base Erosion (GloBE) rules.

What you will learn:

  • How IIR, UTPR, and QDMTT work together as a three-tier top-up tax system — and which rule takes priority
  • The five core formulas for calculating Effective Tax Rate (ETR), Substance-based Income Exclusion (SBIE), and Top-up Tax
  • How the January 2026 Side-by-Side Safe Harbour and new permanent safe harbours change the compliance landscape
  • Practical GloBE Information Return (GIR) filing guidance, including deadlines and data requirements
  • Real-world case studies including the Apple €13 billion EU tax ruling
  • How Pillar Two impacts M&A, tax incentives, investment funds, and IAS 12 accounting disclosures
  • Country-by-country implementation status across 50+ jurisdictions

Updated for 2026 with the latest OECD administrative guidance, the Side-by-Side package for US GILTI coordination, extended transitional safe harbours, and new permanent safe harbour rules.

Whether you are building your Pillar Two compliance framework from scratch or refining an existing process, this book gives you the technical depth and practical clarity to get it right.

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