With the OECD's final regulatory package on Pillar 2 and the corresponding EU draft directive, corporations must prepare to comply with the regulations resulting from BEPS 2.0. Affected are groups with consolidated group sales of EUR 750 million or more. The scope is comparable to the groups that already prepare a country-by-country report of multinational groups. The implementation into national law has to take place by December 31, 2022. As a result, many detailed questions have not yet been conclusively clarified, which means that there may still be significant changes to the rules of the game. This also includes the dispatch of "GloBe Information Returns" and "Notification forms".
In Germany alone, around 800 corporate groups are affected. They still have to tackle implementation in 2022, as the EU directive on implementation is to be applied as early as 01.01.2023¹ and a procedural and technical implementation of the regulatory framework can take several months.
Pillar 2 or the so-called GloBE regulations provide for a global minimum tax of 15 percent on a separate tax base to be determined in a complex manner. The aim is to ensure effective local taxation of 15 percent in each jurisdiction in which one or more group companies or permanent establishments (referred to as constituent entities) are located.
¹ECOFIN meeting of March 15, 2022: Plans to postpone the deadline for transposing the directive into national law by one year to Dec. 31, 2023, and thus also to postpone the first-time application of the Income Inclusion Rule to fiscal years beginning on or after Jan. 1, 2024
Group-wide technical support
With the Pillar 2 module in the GTC suite, AMANA offers group-wide technical and organizational support for companies in meeting this challenge. Central points here will be the manual and machine data collection (centralized and/or decentralized), documentation and evaluation of the data, which will ultimately be the basis of your determination or declaration.²
²The final calculation can be done by the user based on this data or on the basis of the corresponding reports.
The core features of the Pillar 2 module
- Data entry sheet for the GloBE assessment base and the Adjusted Covered Taxes per Constituent Entity
- Automatic data aggregation per country via reports
- Master data transfer from other modules of the GTC suite to avoid duplicate master data maintenance
- Individual/company-specific role and authorization concept
- Period concept for planning or simulations
- Milestone concept 4 eyes principle
- Flexible connection of data sources via CSV import, web service and other standard interfaces
- Transfer of IFRS or tax values from other modules of the GTC suite
- Documentation of adjustments with attachments or comments
- Integrated knowledge via infoboxes
- Adjustments for country specifics possible within the limits of the GloBE corset bars³
- Determination or documentation of carve out facts, e.g. via attachments / Excel etc.
- Flexible reports and evaluation possibilities
³The data entry schemas can be extended by AMANA in consultation with you or your consultant to reflect group specifics or country specifics.
Cooperation partner WTS
In order to ensure topicality and practical relevance, we are developing the Pillar 2 solution in cooperation with WTS. Our cooperation partner WTS supports us with experts in international tax, tax accounting and reporting as well as digitalization to implement the extensive and complex rules in the Pillar 2 module.
Of course, we follow the current developments together. In particular, the possible reporting path is monitored in order to integrate existing interfaces (Elster, Elmar or BOB) or to implement an additional reporting path.