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. In Germany, a minimum taxation directive implementation law was published in draft form on 11.07.2023 accordingly.
In Germany alone, around 800 corporate groups are affected. They still have to tackle implementation in 2023, as the EU directive on implementation is to be applied as early as 01.01.2024 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.
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.1
1The 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 taking into account additional blending circuits, for example through joint venture
- 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 with 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 bars2
- Determination or documentation of carve out facts, e.g. via attachments / Excel etc.
- Flexible reports and evaluation possibilities
2The data entry schemas can be extended by AMANA in consultation with you or your consultant to reflect group specifics or country specifics.
Fast data acquisition
As an additionally licensable module of the GTC suite, the Pillar 2 module can be activated without any further IT requirements so that data can be quickly collected and analyzed.
Thus, the Pillar 2 module of the GTC Suite represents the optimal basis for decentralized acquisition of data for determination and for making it available centrally as a basis for calculations.
The data entry scheme can be extended or adapted in coordination with you or your consultant, e.g. to reflect group or country specifics or to integrate additional calculations.
Cooperation partners
In order to ensure up-to-date information and practical relevance, we work closely with our cooperation partners as well as with our customers. If you have any comments or requests regarding our technology solution, you are therefore invited to write an email to our experts.
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. Interfaces to the BZSt for filing the Global Information Return as well as for filing the tax return in Germany are planned.
Webinar
In our webinar, we will provide an overview of the development status of the Pillar 2 module, and in particular, we will also discuss the embedding of the safe harbor rules.
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