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Pillar 2: Are you ready?

Pillar 2 will establish a global minimum tax regime which will apply to both public and privately held multinational groups with consolidated revenue over €750m. Global agreement has been reached to bring these rules into law and the OECD has released model rules.

The EU released a draft directive requiring EU member states to introduce the rules by 31 December 2023. In the UK it was confirmed on 14 June 2022 that the UK rules are intended to apply for accounting periods commencing on or after 31 December 2023. These dates are subject to final confirmation and draft legislation will be issued in Summer 2022.

Given the tight timeline, the key actions for groups falling within the scope of the minimum taxation rules will be to assess the impact and prepare resources for the additional compliance requirements, to communicate the effects to the stakeholders and train teams. It starts now!

How we can help


We help assess and model the likely financial and operational consequences of Pillar 2.

Services include:

  • Training and upskilling your staff on Pillar 2
  • Initial modelling to understand both Pillar 2 financial impact and process impact on key jurisdictions
  • Deep dive on key jurisdictions to identify both Pillar 2 financial impact and data gap impact
  • Assessment of whether it may be beneficial to make operational or structural changes
  • Stakeholder communications.


We can enhance your reporting and data analytics capabilities.

Services include:

  • Detailed modelling to provide the data for financial disclosures
  • Validate deferred balances ahead of first Pillar 2 reporting period
  • Updates to ERP/CPM processes
  • Review tax reporting process and the use of technology to automate / streamline
  • Consulting on tax accounting treatment, review of disclosures.


We help you meet your ongoing reporting and compliance obligations

Services include:

  • Support the development and configuration of modelling and compliance solutions using your existing systems (such as Oracle, SAP, OneSource, Longview etc) or your internally developed solution
  • Implement our own Pillar 2 tools to help reduce the time and cost associated with your future reporting and compliance obligations
  • Documentation of Pillar 2 related processes and controls to align with tax governance frameworks.


Contact us

Matt Ryan

Matt Ryan

Partner, Tax, PwC United Kingdom

Tel: +44 (0)7718 981211

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