Bart Le Blanc

Large multinational enterprises with a global turnover of at least €750 million ($820 million) will be within the scope of pillar two. The income inclusion rule (IIR) of the OECD’s pillar two proposal will generally impose an additional tax on the (ultimate or designated surrogate) parent company of the MNE group if a foreign subsidiary is effectively taxed below 15%.

As of 1 January 2024, the Income Inclusion Rule (IIR) of the OECD Pillar 2 proposal will impose an additional tax on the ultimate parent company of a group if a foreign subsidiary is effectively taxed below 15%. In this way, Pillar 2 introduces a global minimum tax system with a minimum effective tax rate (ETR) of 15% at the jurisdictional level. Large multinational enterprises with a global turnover of at least €750 million will be within the scope of Pillar 2.