Why a OECD Pillar Two Impact Assessment is Critical

OECD Pillar Two is not simply an increase in tax rates. It introduces an entirely new tax calculation framework based on the OECD's Global Anti-Base Erosion (GloBE) Rules

Many businesses assume that operating in a jurisdiction with a tax rate below 15% automatically results in a top-up tax. In reality, the position depends on several factors, including GloBE income, covered taxes, substance-based carve-outs, safe harbours, and group-wide tax attributes.

A timely assessment can help organizations:

  • Determine whether the group falls within OECD Pillar Two scope
  • Evaluate potential UAE DMTT exposure
  • Understand the impact on Free Zone structures
  • Identify available exemptions and carve-outs
  • Assess data and reporting requirements
  • Develop a proactive compliance strategy

Our Pillar Two Impact Assessment Services:

  • Scope & Applicability Assessment
  • Group Structure & Jurisdiction Review
  • Effective Tax Rate (ETR) & Top-Up Tax Modelling
  • Carve-Out & Relief Review
  • Risk, Readiness & Action Planning

Why a Pillar Two Readiness & Impact Assessment is Critical?

  • Identify potential top-up tax exposure early by assessing Effective Tax Rates (ETRs), safe harbours, and jurisdiction-specific impacts before compliance obligations arise.

  • Avoid costly compliance failures resulting from incomplete data, inaccurate calculations, missed registrations, or delayed filing of Pillar Two returns and notifications.

  • Evaluate the impact on existing structures and operations to determine whether current holding, financing, and operating models remain tax-efficient under the global minimum tax framework.