Groups with consolidated revenue exceeding EUR 750 million fall within the scope of Pillar Two. The Netherlands has fully implemented Pillar Two legislation, including the Income Inclusion Rule (IIR), Qualified Domestic Minimum Top-Up Tax (QDMTT) and, as from FY25 onwards, the Undertaxed Profits Rule (UTPR). 

The Dutch Pillar Two legislation generally follows the OECD Model Rules and accompanying guidance. 
Many groups have meanwhile finalized their Pillar Two filings for FY24. The attention is thus now shifting to FY25. 

Key compliance obligations

Multinational groups with Dutch entities may need to comply with one or more of the following obligations:

  • GloBE Information Return (GIR)
    The GIR contains comprehensive information regarding the Pillar II position of the entire group. The GIR must generally be filed within 15 months after the end of the fiscal year. For FY25, the filing deadline for groups with a 31 December year-end is 31 March 2027.
  • GIR Notification
    Where the GIR is filed in another jurisdiction, submitting a GIR notification with the Dutch tax authorities may be sufficient. A single notification can be filed on behalf of all Dutch entities within the same group. The filing deadline is aligned with the GIR filing deadline.
  • Local top-up tax return
    In contrast with what occurs in some other Pillar II jurisdictions, a Dutch Pillar II tax return is only required where Pillar II top-up tax is payable in the Netherlands. The standard deadline is 17 months after the end of the reporting fiscal year. For FY25, the filing deadline for groups with a 31 December year-end is 31 May 2027.

Lessons learned from FY24

The key lesson from the first year of Pillar Two compliance is straightforward: start early.

FY 25 deadlines are shorter than those applicable for FY24 and may coincide with other external reporting obligations. In addition, the UTPR becomes effective from FY25, increasing the number of calculations and technical analyses required. 

More jurisdictions, such as Singapore and Hong Kong, have implemented Pillar Two rules as of 2025. For Groups that require external support with their FY25 Pillar Two compliance process, it is advisable to engage advisers at an early stage. Defining the scope of work, appointing (local) providers, and coordinating across multiple jurisdictions can take considerable time. 

Finally, where the GIR will be filed in a different jurisdiction from FY24, this decision should be made early in the process.

Late changes may result in additional administrative requirements, including potentially resubmission of GIR notifications.

New in scope of Pillar Two

Will your group be in scope of Pillar Two for FY 25 or FY26 for the first time? Early preparation is essential, even though first-year filing deadlines are extended by 3 months. 

Key preparatory activities include:

  • Assessing the Pillar Two impact on your group
  • Determining filing and reporting obligations in the various jurisdictions
  • Implementing appropriate technology
  • Establishing governance and internal responsibilities
  • Validating the availability and quality of the required data
  • Performing entity classifications
  • Verifying safe harbour eligibility, including safe harbour calculations
  • Define filing strategy and implement action plan for ensuring compliance.

Completing a Pillar Two impact assessment in advance helps avoid unexpected outcomes later in the process. 

For example, the applicable Dutch statutory tax rate of 25.8% does not necessarily mean that by default no Pillar II tax would be due in the Netherlands. In practice, we have seen Pillar II tax liabilities arisen in the Netherlands due to losses available for carry-forward in combination with investment allowances or temporary differences in combination with the innovation box. 

How RSM can help

At RSM, we continue to support multinational groups with Pillar Two impact assessments, readiness projects, compliance and technology solutions. Our team offers:

  • Extensive Pillar Two expertise through RSM’s international network;
  • Practical experience in embedding Pillar Two process within existing finance and tax functions;
  • Advanced data-analytic capabilities and hands-on experience with Pillar Two technology solutions;
  • Support with GIR filings, notifications, and local Pillar Two return;
  • Assistance with Pillar Two disclosures in statutory and consolidated financial statements;
  • Coordination of multi-jurisdictional Pillar Two compliance projects; and
  • Tax technology solutions for ensuring Pillar Two compliance.

Would you like to understand how Pillar Two may affect your group?

Please feel free to contact us.
 

Do you have a question? We will get back to you as soon as possible.