Skip to main content

BEPS 2.0: Pillar Two

KPMG insights about the impact of the Pillar Two—global minimum tax rules—and how companies are responding

Pillar Two Insights Center

Gain forward-thinking insights on BEPS 2.0 Pillar Two regulations.

Subscribe

The OECD/G20 Inclusive Framework on BEPS reached agreement on the Pillar Two global minimum tax rules in October 2021, putting out model rules in December 2021, commentary in March 2022, and further administrative guidance in February 2023. These new Global Anti-Base Erosion (GloBE) rules are now being implemented by jurisdictions around the world and will apply to many companies from 2024. Multinational companies need to stay abreast of these developments to navigate and prepare successfully for the changes in the global tax landscape.

You'll find insights from KPMG about these developments on this page.

Dive into our thinking:

KPMG BEPS 2.0 Automation Technology

Modeling for the changing global tax landscape – Learn more about the multiplatform tool that allows for both high-level and detailed modeling of BEPS 2.0 Pillar Two provisions, including safe harbor calculations.

Download PDF

BEPS developments from KPMG TaxNewsFlash

TaxNewsFlash-BEPS | Access all alerts

KPMG Pillar Two webcasts

Insight
Webcast Replay Webcast Upcoming Listen Now From The Web

January 13, 2026 | The Pillar Two Side-by-Side Deal: What Does It Mean for MNEs and Where Do We Go From Here?

On this TaxWatch webcast, Washington National Tax professionals discuss the OECD's Pillar Two framework and the recent release of the "side-by-side" agreement.

Read more
Insight
Webcast Replay Webcast Upcoming Listen Now From The Web

August 13, 2025 | Tax Policy Trifecta: Exploring How the G7 Statement Impacts US Multinationals from a Pillar Two Perspective

During this webcast, professionals from the KPMG Washington National Tax office will discuss the implications of the G7 Statement from a 2024/2025 Pillar Two compliance and financial reporting perspective. The webcast will highlight a variety of considerations U.S.-based businesses should think about now when preparing for Pillar Two. 

Read more
KPMG TaxRadio podcasts
No results found.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

January 13, 2026 | Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?

In this episode of Inside International Tax, we examine the impact on US and foreign multinationals of the OECD’s Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

December 19, 2025 | Taxing Times: 2025 Transfer Pricing Recap and Beyond

On this episode of Exploring Transfer Pricing, we highlight how policy changes, including tariffs, are reshaping transfer pricing approaches and risk management.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

August 1, 2025 | From the OB3 to the OECD: What Does the G7 Agreement Mean for Pillar Two?

In this episode of Inside International Tax, we discuss the implications of the “side-by-side” solution agreed to by the G7 and its impact on Pillar Two.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

May 8, 2025 | The Art of the Global Tax Deal: The US Negotiates with the OECD on Pillar Two

In this episode of Inside International Tax, we discuss the concessions the United States is seeking from the OECD’s Inclusive Framework on the Pillar Two regime to protect U.S. multinationals from over-taxation and the potential international response to these demands.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

November 25, 2024 | What is the Interaction Between Pillar Two and Transfer Pricing?

On this episode of Exploring Transfer Pricing, we delve into understanding the critical link between Pillar Two and transfer pricing.
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

June 26, 2024 | A Tale of Two Pillars, Part II

Inside International Tax podcast: A Discussion with Michael Plowgian on the Current State of Pillar Two
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

June 6, 2024 | A Tale of Two Pillars, Part I

Inside International Tax podcast: A Discussion with Michael Plowgian on the Current State of Pillar One
iconimg Insight
Webcast Replay Webcast Upcoming Listen Now From The Web from the web

February 08, 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

What guidance does Notice 2023-80 give regarding the interaction of GloBE rules with foreign tax credits and dual consolidated losses?

February 08 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

    KPMG reports and articles

    How Can Pillar Two Compliance Offer New Business Opportunities?

    How Can Pillar Two Compliance Offer New Business Opportunities?
    The Intersection of Pillar Two and M&A Tax

    The Intersection of Pillar Two and M&A Tax
    BEPS and Pillar Two Are Here - Where in the GLoBe Are Your Employees?

    BEPS and Pillar Two Are Here - Where in the GLoBe Are Your Employees?
    Recent DCL and Pillar 2 Guidance: Comments and Recommendations

    Recent DCL and Pillar 2 Guidance: Comments and Recommendations
    Leveling the Pillar Two Playing Field for the Asset Management Industry

    Leveling the Pillar Two Playing Field for the Asset Management Industry
    Pillar Two Implications of U.S. Self-Initiated Transfer Pricing True-Ups

    Pillar Two Implications of U.S. Self-Initiated Transfer Pricing True-Ups
    Foreign Tax Credits for Multinationals Involve a Winding Path

    Foreign Tax Credits for Multinationals Involve a Winding Path
    Transfer Pricing Implications of Pillar Two Minimum Tax Rules

    Transfer Pricing Implications of Pillar Two Minimum Tax Rules
    Pillar Two Watch Out: Is There a U.S. Sandwich in Your Structure?

    Pillar Two Watch Out: Is There a U.S. Sandwich in Your Structure?
    Gearing up for Pillar Two Operational Readiness

    Gearing up for Pillar Two Operational Readiness
    Despite Relief, Pillar Two Problem Remains for US Multinationals

    Despite Relief, Pillar Two Problem Remains for US Multinationals
    Pillar Two: Subject to Tax Rule

    Pillar Two: Subject to Tax Rule
    Pillar Two: GloBe Information Return

    Pillar Two: GloBe Information Return
    Global Minimum Tax

    Global Minimum Tax
    Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

    Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)
    Stronger Case for Stock Based Compensation Recharges under OECD Pillar Two

    Stronger Case for Stock Based Compensation Recharges under OECD Pillar Two

    Related insights and resources

    BEPS

    KPMG TaxNewsFlash reports about OECD's base erosion and profit shifting (BEPS) initiative and tax transparency

    Read more
    Insight
    Webcast Replay Webcast Upcoming Listen Now From The Web

    Pillar Two compliance

    Under the new OECD Pillar Two minimum tax regime, companies now face new complex tax reporting requirements. Many multinational enterprises (MNEs) impacted by Pillar Two have already started preparing for these new reporting requirements.

    Read more
    Resource
    Webcast Replay Webcast Upcoming Listen Now From The Web

    Checking in on Pillar Two

    Wondering what’s been going on with Pillar Two? Read our Hot Topic to find out.

    Read more
    Insight
    Webcast Replay Webcast Upcoming Listen Now From The Web

    Navigating the new realities of Pillar Two compliance

    As new global tax regulations take effect, here’s a closer look at the emerging challenges – and the leading practices to address them.

    Read more
    Insight
    Webcast Replay Webcast Upcoming Listen Now From The Web

    Taxation of the Digitalized Economy: Developments Summary

    Overview of how countries are responding to the challenges arising from the digitalized economy

    Read more
    Global Tax Reform

    Global Tax Reform

    BEPS and Tax Transparency: Insights on the drivers of global tax reform affecting multinational companies

    Read more

    Be ready for disruption - tax insights

    Tax insights and analysis to help organizations respond with speed and confidence

    Read more

    Explore services

    globe

    Digital Gateway Modeling Suite

    Discover the far-reaching power of tax models with KPMG Digital Gateway.

    Learn more
    spinner

    International Tax

    Helping multinational organizations succeed in the current complex international tax environment. 

    Learn more
    divergent lines

    Transfer Pricing

    Advising on the constantly evolving tax laws, regulations, and economic pricing methods. 

    Learn more
    resolution

    Tax Controversy & Dispute Resolution Services

    A coordinated approach to tax controversary multinationals. 

    Learn more

    Meet our team

    Image of Danielle E. Rolfes
    Danielle E. Rolfes
    Partner in Charge, Washington National Tax, KPMG US
    Read bio
    Image of Kevin J. Brogan
    Kevin J. Brogan
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Marcus Heyland
    Marcus Heyland
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Quyen Huynh
    Quyen Huynh
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Michael H. Plowgian
    Michael H. Plowgian
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of John DerOhanesian
    John DerOhanesian
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Alistair Pepper
    Alistair Pepper
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Marissa K. Rensen
    Marissa K. Rensen
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Federica Porcari
    Federica Porcari
    Senior Manager, Washington National Tax, KPMG US
    Read bio
    Image of Danielle E. Rolfes
    Danielle E. Rolfes
    Partner in Charge, Washington National Tax, KPMG US
    Read bio
    Image of Kevin J. Brogan
    Kevin J. Brogan
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Marcus Heyland
    Marcus Heyland
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Quyen Huynh
    Quyen Huynh
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of Michael H. Plowgian
    Michael H. Plowgian
    Principal, Washington National Tax, KPMG US
    Read bio
    Image of John DerOhanesian
    John DerOhanesian
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Alistair Pepper
    Alistair Pepper
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Marissa K. Rensen
    Marissa K. Rensen
    Managing Director, Washington National Tax, KPMG US
    Read bio
    Image of Federica Porcari
    Federica Porcari
    Senior Manager, Washington National Tax, KPMG US
    Read bio

    Pillar Two Insights Center

    Gain forward-thinking insights on BEPS 2.0 Pillar Two regulations.

    Subscribe

    Thank you

    You are subscribed to receive Pillar Two related insights.

    Subscribe to Pillar Two Insights Center

    Receive essential updates on BEPS 2.0 Pillar Two. Focused on the evolving landscape of global minimum tax rules, each issue aims to equip tax professionals and business leaders with crucial information to help your organization effectively adapt to the evolving tax changes.

    All fields with an asterisk (*) are required.

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

    An error occurred.

    KPMG. Make the Difference.


    Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

    The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

    The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

    © 2026 KPMG LLP, a Delaware limited liability partnership, and its subsidiaries are part of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

    For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

    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.
    All fields with an asterisk (*) are required.

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

    An error occurred.

    Job seekers

    Visit our careers section or search our jobs database.

    Search now!

    Submit RFP

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

    Submit

    Office locations

    View locations

    International hotline

    You can confidentially report concerns to the KPMG International hotline

    Learn more

    Press contacts

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

    Contact

    Headline