Pillar Two Readiness, Scoping, & Impact Assessment
For many MNEs, Pillar Two raises critical threshold questions early: whether the rules apply, which jurisdictions are in scope, and where potential top-up tax exposure may arise. Forvis Mazars helps MNEs assess applicability under the OECD Global Anti-Base Erosion Rules (GloBE) framework, evaluate constituent entities, and identify jurisdictions where exposure may emerge. Our structured scoping and impact assessments provide early visibility into risk areas and support informed decisions on governance, resourcing, and next steps.
Pillar Two Data Strategy & Collection
MNEs often face significant data challenges under Pillar Two, particularly where required GloBE data extends beyond traditional tax reporting processes. Data may reside across ERPs, payroll systems, statutory accounts, and local finance teams outside the United States. Forvis Mazars helps organizations design a centralized Pillar Two data strategy tailored to global structures, identify data gaps, and streamline collection using a cloud-based, adaptive data questionnaire. This approach focuses local teams on only relevant data, improving data quality while reducing disruption and escalation risk.
GloBE Calculations & OECD Pillar Two Compliance
OECD Pillar Two establishes a global minimum tax framework that requires detailed, jurisdiction‑level GloBE calculations for many MNE groups, with applicability varying by ownership structure and local implementation of the Income Inclusion Rule (IIR), Under‑Taxed Profits Rule (UTPR), and Qualified Domestic Minimum Top‑Up Tax (QDMTT). While certain U.S.-parented groups may be excluded from the IIR and UTPR as early as 2026 under the recent OECD commentaries concerning Side‑by‑Side Regimes, they may still face QDMTT obligations and related compliance requirements in foreign jurisdictions.
Forvis Mazars supports U.S. and non‑U.S. MNEs with consistent, defensible GloBE calculations aligned with OECD guidance and local legislation. We help groups assess scope early, apply available safe harbors and transitional relief, manage complex structures, evaluate effective tax rate impacts, and prepare required notifications and filings, including the GloBE Information Return (GIR) and QDMTT filings, with confidence.
Pillar Two Filing Readiness & Global Coordination
As jurisdictions outside the U.S. begin enforcing Pillar Two, MNEs face varying registration, notification, and filing obligations across countries and timelines. Forvis Mazars helps clients with their GIR filings by coordinating data, calculations, and reporting outputs through centralized workflows. We support proactive tracking of local requirements, alignment across regions, and audit-ready documentation, enabling teams to maintain control while meeting decentralized filing demands.
Learn more about upcoming Pillar Two filing deadlines
Pillar Two Technology & Automation Solutions
Sustainable Pillar Two compliance requires more than a one-time analysis. Forvis Mazars helps MNEs move away from spreadsheet-driven processes toward technology-enabled Pillar Two solutions that support ongoing governance. Our integrated Pillar Two Tool serves as a single source of truth for entity data, calculations, and reporting, helping tax, finance, and IT teams reduce manual effort, improve consistency, and scale compliance as global requirements continue to evolve.
