Pillar Two (global minimum tax)

Roles that need it

• Tax Associate
• Group Reporting Accountant
• Transfer Pricing Analyst
• External Audit Associate

Skills it belongs to

• Corporate taxation
• Group consolidation

Related concepts

• Deferred taxDeferred tax is the tax effect of temporary differences between the accounting carrying amount of assets and liabilities and their tax base. IAS 12 recognises deferred tax liabilities and, when future taxable profit is probable, deferred tax assets, including those from tax losses.
• Transfer pricingTransfer pricing sets the prices of transactions between entities of the same group, such as services, loans, guarantees and intangibles. Tax rules require the arm's length principle: prices independent parties would agree. OECD guidelines set methods and documentation (master file and local file).
• Permanent establishment (PE)A permanent establishment is a fixed place of business, or in some cases a dependent agent, through which a company carries on business in another country. The profits attributable to it can be taxed there, so branches and people working abroad need careful review.

Sources

• Council Directive (EU) 2022/2523 on a global minimum level of taxation, EUR-Lex (external site) accessed 31 Oct 2026

Updated 31 Oct 2026.