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Pillar Two

Turn Pillar Two into trustful compliance with our tech-enabled approach

Pillar Two implementation brings complex challenges for multinational groups with consolidated revenue over €750 million. The Pillar Two’s 15% global minimum tax requires you to adapt your systems, technology, processes, governance and control to meet evolving data and compliance requirements. Done right, this creates opportunities for future growth.

Our end-to-end tech-enabled approach through Sightline, driven by the Pillar Two Engine, helps you quickly calculate the Pillar Two impact and meet your compliance obligations. With our global network of international tax specialists, we tackle complexity together. We help deliver value across the full compliance lifecycle: initial assessment through to compliance and reporting.

Video 23/07/24

PwC’s Pillar Two Engine, powered by Beacon

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How we can help

Data strategy

Identifying the data requirements and developing a comprehensive data strategy are your first steps in preparation for Pillar Two. You’re managing multiple data sources across diverse stakeholders—and that makes collection and synthesisation complex. Early cross-functional engagement cuts through this complexity: it helps you get the right data and helps your system owners understand what Pillar Two demands. We help you build a data strategy rooted in systems and processes that streamline reporting and compliance.

Our Pillar Two Data Input Catalogue acts as the foundation to develop an extensive data strategy, assess operational preparedness and determine your calculation approach. This crucial tool outlines the comprehensive data requirements for Pillar Two and serves to identify and map the data you need for calculation and compliance obligations. The dynamic, globally governed catalogue covers all necessary data for the qualified domestic minimum top-up taxes (QDMTTs), the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR). It includes essential information for forms as they become available.

The Data Input Catalogue powers our Sightline questionnaire—designed to streamline your data-collection process. It narrows down the scope of relevant data for Pillar Two reporting and compliance. It captures entity-level data that is not centrally available. The information gathered by the Sightline questionnaire feeds our Pillar Two Engine, which performs your Pillar Two calculations.

Pillar Two Engine

Pillar Two Engine, powered by Beacon, is our centralised, cloud-based solution designed to quantify the impact of Pillar Two, including provision, compliance and modelling. Its centralised rule library is regularly updated by international tax specialists. It adapts to evolving local regulations and interpretations—ensuring your global and statutory compliance.

Built on Beacon graph technology, the Pillar Two Engine delivers precise, visually traceable results to support various calculations—including the GloBE Rules and country-specific legislation—and produces multiple data points for your various compliance destinations.

The Pillar Two Engine produces deliverables for all your compliance needs, including the GloBE Information Return (GIR) and local tax forms in XML format. It identifies reporting discrepancies between the GIR and QDMTT rules. It simplifies complex cross-border filing requirements and streamlines the preparation and submission of your Pillar Two tax returns.

We continually enhance the Pillar Two Engine’s capabilities, delivering a comprehensive solution for your Pillar Two reporting and filing obligations, positioning you for strategic growth while staying ahead of evolving requirements.

Pillar Two compliance

Managing Pillar Two compliance across global operations brings real complexity. Registration, notification, filing and payment requirements across multiple jurisdictions require constant monitoring to maintain timely adherence to local rules. Our Pillar Two Country Tracker helps you follow Pillar Two adoption and compliance deadlines in more than 100 countries.

We help you protect your value and stay ahead of Pillar Two compliance challenges with confidence through our connected tax compliance methodology. Our seasoned specialists and advanced technologies, led by Sightline and the Pillar Two Engine, streamline your Pillar Two tax compliance process by connecting people, data, and insights seamlessly delivering a faster, smarter, and more efficient experience.

Operational readiness

Pillar Two can have widespread impact on your financial operating model, requiring early stakeholder engagement and potentially additional budget. The key question: can your current data model, systems, technology and processes support the requirements of this new international tax framework?

We help you assess your operating model and processes, identify gaps and design solutions for enhanced governance and efficiency—preparing you for successful Pillar Two implementation.

Our tools with alliances

Our alliances partners help us tackle Pillar Two’s toughest challenges. They enable your existing ERP, ETL (extract, transform and load) and cloud data infrastructure to become more powerful—identifying, sourcing and transforming data for new Pillar Two processes. This integration strengthens what you already have.

Achieve a truly unified experience by feeding this data into PwC’s Pillar Two Engine, ensuring you effortlessly meet all Pillar Two reporting and filing obligations with precision and confidence.

Together with our alliances, you can make compliance work for your business growth.

Artificial intelligence

AI enhances the insights, quality and value of our Pillar Two process. From data collection to understanding calculations in the Pillar Two Engine to interpreting country global minimum tax laws.

Our AI transforms how you meet Pillar Two compliance. It maps your data to standardised frameworks of Pillar Two accounts and adjustments—ensuring full compatibility with our Pillar Two Engine. Explore data deeper and uncover new insights. Interact with calculation results differently. Understand complex calculations. Identify differences between local legislation and OECD model rules.

Ready to transform your Pillar Two approach?

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Doug McHoney

Doug McHoney

International Tax Services Leader, Global Tax & Legal Services, PwC United States

Jonathan Howe

Jonathan Howe

Global Connected Tax Compliance Leader, PwC United Kingdom

Tel: +44 (0) 7970 474343

William Morris

William Morris

Global Tax Policy Leader, PwC United States

Anthony Sciarra

Anthony Sciarra

Pillar Two Data Strategy Global Leader, PwC United States

Michael Olecki

Michael Olecki

International Tax Services Global Technology Leader, Partner, PwC United States

Erin Callanan

Erin Callanan

Partner - Tax Reporting & Strategy, PwC United States

Matt Ryan

Matt Ryan

Partner, Tax, PwC United Kingdom

Tel: +44 (0)7718 981211

Shintaro Yamaguchi

Shintaro Yamaguchi

Partner, PwC Tax Japan

Jesse Kavanagh

Jesse Kavanagh

International Tax and Tax Reporting and Strategy partner, PwC China

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