Pillar 2 and Country-by-Country-Reporting (CbCR)

The Pillar Two rules aim to ensure the biggest multi-national businesses pay tax at a minimum effective tax rate of 15%. These global minimum tax rules apply to groups with income of at least €750m. Where a business within a multinational group has an effective tax rate of below 15%, the Pillar Two rules may require a top-up tax to be paid. These rules are one of the key outputs of the Organisation for Economic Cooperation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project, which was undertaken to make the international tax system fit for a global, digital economy.

We help businesses understand and manage their Pillar 2 and Country-by-Country Reporting obligations in Gibraltar. This includes:

• reviewing group structures and revenue thresholds;
• identifying whether Pillar 2 and/or CbCR rules apply;
• mapping Gibraltar filing, notification and payment obligations;
• acting as tax agent for the Gibraltar entity
• preparing clear timelines and data requirements.

With our support, you will receive clear, practical guidance and a structured approach to meeting your international tax reporting obligations.

How can we help you?

We would be delighted to discuss how we can help, so please get in touch with us today!