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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.

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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.

BEPS 2.0 State of Play Summary

High-level overview of administrative and legislative developments in jurisdictions around the world related to the implementation of Pillar Two

Download PDF Interactive dashboard

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.

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BEPS developments from KPMG TaxNewsFlash

TaxNewsFlash-BEPS | Access all alerts

KPMG Pillar Two webcasts

Insight
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Real Estate Tax Chat: A Focus on Pillar 2 and the Proposed Section 987 Regulations

Real Estate Tax Chat: A Focus on Pillar 2 and the Proposed Section 987 Regulations

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April 18, 2024 | Finance’s role in Pillar Two Enablement

Join the Finance’s role in Pillar Two Enablement webcast hosted by KPMG.

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Webcast: Pillar Two: Frequently asked questions
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January 24, 2024 | Pillar Two: Frequently Asked Questions (Part One)

KPMG professionals share insights on frequently asked questions about implementing Pillar Two covering tax, accounting and audit topics.

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Pillar Two Gameplan

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Pillar Two Gameplan – Executive summary

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

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Pillar Two pregame show - Episode 5
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Pillar Two pregame show - Episode 5

Playing the long game: Strategizing for the future effects of Pillar Two.

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Pillar Two pregame show - Episode 4
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Pillar Two pregame show - Episode 4

Officiating the Rules: Navigating the accounting and audit considerations.

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Resource
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Podcast: Pillar Two pregame show - Episode 3

Going the distance: Diving deep into the Globe ETR calculation and its many challenges.

Learn more November 13, 2023
Insight
Webcast Replay Webcast Upcoming Listen Now

Pillar Two Pregame Show: Episode Two

Simplifying the game - Getting to know the safe harbor

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Insight
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Pillar Two Pregame Show: Episode One

Blocking and tackling: Understanding the fundamentals of Pillar Two

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KPMG TaxRadio podcasts
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Webcast Replay Webcast Upcoming Listen Now

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
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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
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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!
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October 4, 2023 | Pillar Two Reloaded: Second Round of OECD Guidance

Podcast: What guidance was released in the second round of OECD Pillar Two guidance and where do we stand on the implementation of GloBE rules?

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June 30, 2023 | P2 and Congress: It’s Complicated

Podcast on legislative negotiations in Washington and how the divided Congress could come to terms with Pillar Two
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June 28, 2023 | Ready, Set, GloBE!

Podcast: How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
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March 29, 2023 | I Literally CAMT: Dealing with Your International Min Tax Issues

Podcast: What are the most pressing CAMT international tax issues for which taxpayers need guidance today?
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February 1, 2023 | What to Expect when You’re Expecting Pillar Two

Podcast discusses when U.S. multinationals can expect the GloBE rules to come on line and how those rules may impact them
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October 5, 2022 | A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

Podcast: What GloBE rules should you consider in structuring M&A transactions today?

    KPMG reports and articles

    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

    KPMG International Tax videos

    Insight
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    Pillar Two Challenges: Book Accounting and GloBE Income Calculation

    International Tax Team video series – Overview of the book accounting considerations when calculating GloBE income under Pillar Two (part 4)

    Read more
    Insight
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    Pillar Two Challenges: Data Gaps, Technology Needs, and Modeling

    International Tax Team video series – Overview of the implementation challenges that the OECD’s Pillar Two presents beyond the tax technical (part 3)

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    Pillar Two Implementation: U.S. Multinationals Impacts and Considerations
    Insight
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    Pillar Two Implementation: U.S. Multinationals Impacts and Considerations

    International Tax Team video series – Overview of the impact of the OECD’s Pillar Two initiative on U.S. multinational groups (part 1)

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    Related insights and resources

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    Pillar Two compliance

    Under the new 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

    Checking in on Pillar Two

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

    Read more
    Insight
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    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
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    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
    Insight
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    Global Tax Reform

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

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    Insight
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    Be ready for disruption - tax insights

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

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    Meet our team

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    Partner in Charge, Washington National Tax, KPMG US
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    Principal, International Tax, Washington National Tax, KPMG US
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    Principal, International Tax, Washington National Tax, KPMG US
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    Alistair Pepper
    Managing Director, Economic & Valuation Services, Washington National Tax, KPMG U.S. Tax Services (London) LLP
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    Image of Danielle E. Rolfes
    Danielle E. Rolfes
    Partner in Charge, Washington National Tax, KPMG US
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    Image of Kevin Brogan
    Kevin Brogan
    Principal, International Tax, Washington National Tax, KPMG US
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    Image of Quyen Huynh
    Quyen Huynh
    Principal, International Tax, Washington National Tax, KPMG US
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    Image of Marcus Heyland
    Marcus Heyland
    Principal, Washington National Tax, KPMG US
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    Image of Alistair Pepper
    Alistair Pepper
    Managing Director, Economic & Valuation Services, Washington National Tax, KPMG U.S. Tax Services (London) LLP
    Read bio

    Pillar Two Insights Center

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