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      Many multinational enterprises (MNEs) need to prepare for new tax legislation around the world that will impose a minimum rate of tax in each jurisdiction where the MNE operates globally. Based on Pillar Two of the Organization for Economic Cooperation and Development’s (OECD) base erosion and profit shifting (BEPS) project, these rules are complex and have taken effect in some countries as of January 1, 2024. As such, MNEs should act quickly to determine how they are affected. This article discusses practical steps MNEs can take to assess the impact of Pillar Two legislation on their organizations.

      The Fit for Pillar Two series aims to help tax teams of MNEs within the scope of Pillar Two prepare for the upcoming wave of international tax changes by putting theory into practice.

      In this series, Christian Athanasoulas, Tax Practice Leader – Services at KPMG in the US, and Global Head of International Tax and M&A Tax at KPMG International, will provide his insights and draw on experiences from professionals in KPMG member firms worldwide. Articles in the Fit for Pillar Two series will build upon each other and are designed to guide companies through the phases of Pillar Two readiness, focusing on:

      • Is your company ready for Pillar Two’s Global Minimum Tax?
      • Unlocking global opportunities: Strategic tax responses and business restructurings in the era of Pillar Two
      • Data, transformation and technology
      • Compliance and reporting
      • Pillar Two implications to mergers and acquisitions
      • Pillar Two considerations for other departments in your organization
      • Preparation for controversy and dispute resolution

      Fit for Pillar Two series

      This article is designed for those clients just beginning their journey or those that have taken steps forward but need to validate work completed to date.

      This article explores how MNEs can seize global opportunities by implementing strategic tax responses and business restructurings.

      This article explores how Pillar Two interacts with M&A activities, focusing on acquisitions, dispositions, joint ventures, and carve-outs.

      This article explores how business leaders can turn Pillar Two compliance into a competitive advantage.


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      Zubair Patel

      Head of Tax and Legal, KPMG's CASA region, and Head of Tax & Corporate Services

      KPMG in Kuwait

      Fahim Bashir

      Partner — Tax & Corporate Services and Head of Clients & Markets

      KPMG in Kuwait

      Naveen Bohra

      Director — Tax & Corporate Services

      KPMG in Kuwait


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