Helping clients meet their business challenges begins with an in-depth understanding of the industries in which they work. That’s why KPMG LLP established its industry-driven structure. In fact, KPMG LLP was the first of the Big Four firms to organize itself along the same industry lines as clients.

How We Work

We bring together passionate problem-solvers, innovative technologies, and full-service capabilities to create opportunity with every insight.

Learn more

Careers & Culture

What is culture? Culture is how we do things around here. It is the combination of a predominant mindset, actions (both big and small) that we all commit to every day, and the underlying processes, programs and systems supporting how work gets done.

Learn more

Pillar Two Gameplan

Executive Summary | October 2023

Our executive guide to the new rules – with implementation steps, and how accounting and finance may be impacted.

Written with finance professionals in mind, our gameplan provides an overview of the new rules, implementation steps companies should be taking to get ready for Q1, and how the accounting and finance functions may be impacted – including where the external auditor may be focused.


  • Multinational companies with consolidated revenues of at least €750M

Relevant dates

  • 2023 Year-end Reporting – Evaluate whether existing SEC rules require disclosure of the potential effects of Pillar Two
  • January 1, 2024 – Pillar Two rules begin to go into effect
  • Q1 2024 Reporting – Account for the effects of Pillar Two in the interim tax provision

The kickoff:

The new OECD Pillar Two rules and football may seem like two different worlds, but they share surprising similarities. Both involve complex strategies, coordination among players, and the goal of gaining and protecting valuable turf. But while most of us are cheering for our favorite teams this time of year, US multinationals are preparing for the impact of Pillar Two. ​

Pillar Two is a new tax regime aimed at making sure certain multinationals pay their fair share of taxes – 15% to be exact – in every jurisdiction in which they do business. If that minimum tax rate has not been met in a particular jurisdiction, companies will need to make up the shortfall by paying a ‘Top-Up Tax’. ​

But figuring out whether the Top-up Tax is owed is not easy. ​

The Pillar Two rules require complicated and data-intensive calculations of a new effective tax rate measure (the ‘Globe ETR’) for every single jurisdiction in which the company has operations. These calculations are based on a unique hybrid of tax and financial accounting concepts, which will effectively require companies to create a third set of books. ​

While this may seem like a tax-only problem at first glance, Pillar Two is expected to disrupt the finance and controllership functions as well. ​

Time is ticking on the game clock too – we expect many US multinationals to be impacted in the first quarter of 2024, which is when these rules begin to go into effect. ​ 

Calendar-year public companies will be required to report on the forecasted effects of Pillar Two in their 2024 Q1 income tax provision and consider disclosure obligations in their 2023 10-K.​

Given the scope and complexity of the new rules, implementing Pillar Two can seem daunting – think of it as implementing the new revenue and leases standards at the same time. That’s why we’ve drawn up this gameplan to help US companies meet their immediate financial reporting obligations. ​

Written with US professionals (and US GAAP) in mind, our gameplan provides an overview of the new rules, implementation steps companies should be taking to get ready for Q1, and how the accounting and finance functions may be impacted – including where the external auditor may be focused.​

Download the document:

Pillar Two Gameplan

Download PDF

BEPS 2.0: State of play

Download PDF

Explore more

Meet our team

Image of Nick Tricarichi
Nick Tricarichi
Partner, Dept. of Professional Practice, KPMG US
Image of Matt Drucker
Matt Drucker
Partner, Dept. of Professional Practice, KPMG US

Accounting Research Online

Access our accounting research website for additional resources for your financial reporting needs.

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP's Privacy Statement.

An error occurred. Please contact customer support.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.