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Cross-border Tax Talks
July 23, 2026
Portal Combat 2: Pillar Two compliance post-mortem
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Coughlin, a Chicago-based tax director in PwC’s Quantitative Solutions and Technologies Practice within International Tax Services and a former Notre Dame running back. Doug and Pat discuss the June 30, 2026 Pillar Two compliance deadline, including PwC’s experience filing more than 50,000 returns with a success rate above 99%. They dive into how business rules and filing capabilities were built across dozens of jurisdictions, what late portals and conflicting validations revealed about the system, why the OECD and local tax authorities should act quickly on timely-filed GIR relief, a longer 2025 filing deadline, clearer amended-return mechanics, and broader simplification. They close with practical advice for 2025: start now, focus on calculations, and narrow review to the sections that matter most.
- [00:45] Introduction: Comparing the Notre Dame football playbook to Pillar Two rules
- [04:40] Framing the June 30, 2026 Pillar Two compliance post-mortem.
- [05:20] Pat’s background and his ‘opportunity’ to build business rules for TCJA and Pillar Two.
- [08:20] How PwC global and local teams handled rules, forms, and testing.
- [11:55] Overview of the short-term and long-term recommendations:
- Timely-filed GIRs in extended-deadline jurisdictions should count as timely everywhere.
- Extend the 2025 compliance deadline.
- Coordinate and update GIR validations globally.
- Amended returns should not be required before information exchange.
- Long-term - simplification of the GIR and local returns.
- [16:25] How portal delays and local extensions created timely-filing problems.
- [17:40] OECD June fixes, contradictory validations, and blocked XML transmissions.
- [21:35] Receiving-jurisdiction mismatches in Germany and Switzerland.
- [23:30] Why taxpayers need legal certainty on penalties and lost elections.
- [25:40] Why 2025 needs more time: late forms, year-end pressure, and new jurisdictions.
- [28:40] Why UTPR makes the 2025 cycle riskier and more complex.
[30:00] Why validation coordination matters for MCAA and DAC 9 information exchange. - [31:45] Contradictions across the GIR template, XML schema, and validation documents.
- [37:25] Why amended returns and deletions remain operationally unclear.
- [41:00] Long-term simplification: fewer forms, simpler filings, and a leaner XML.
- [42:40] OECD guidance on simpler local filings and earlier form release.
- [45:35] Practical advice for taxpayers starting the 2025 Pillar Two compliance cycle.
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Speakers
International Tax Services Global Leader, PwC US
Pat Coughlin
Director, PwC US
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