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What is OECD Pillar Two?
OECD Pillar Two is a global tax initiative introducing a minimum corporate income tax rate of 15%. The aim is to ensure that multinational enterprises (MNEs) pay a fair share of tax wherever they operate. By doing so, the OECD seeks to combat tax avoidance, profit shifting, and harmful tax competition.
The framework consists of three main rules:
- Income Inclusion Rule (IIR): the parent company pays a top-up tax if a subsidiary is taxed below the minimum rate.
- Undertaxed Profits Rule (UTPR): if the IIR does not apply, other jurisdictions can impose the top-up tax.
- Qualified Domestic Minimum Top-up Tax (QDMTT): allows countries to levy the top-up tax domestically to retain tax revenues.
When does Pillar Two apply in the Netherlands?
The Netherlands has implemented these rules through the Minimum Tax Act 2024.
- IIR and QDMTT: effective for fiscal years starting on or after 31 December 2023.
- UTPR: effective for fiscal years starting on or after 31 December 2024.
Who is affected?
The rules apply to:
- Multinational enterprise (MNE) groups, and
- Large-scale domestic groups
…with annual revenues of EUR 750 million or more in at least two of the four preceding fiscal years.
A transitional rule provides a five-year exemption from IIR and UTPR for groups in the initial phase of international activity.
What does this mean for your organisation?
Organisations should start preparing now:
- Assess scope: determine whether your group exceeds the EUR 750 million threshold.
- Perform an impact analysis: identify financial and strategic implications.
- Update data and reporting systems: to meet the new compliance and filing requirements.
Key deadlines in the Netherlands
- GloBE Information Return: due by 30 June 2026 (for fiscal year 2024).
- Top-up Tax Return and payment: due by 31 August 2026.
In addition, EU-wide obligations under DAC9 will also apply.
How can RSM support you?
RSM Netherlands helps businesses navigate the complexity of Pillar Two compliance. Our services include:
- Deep tax expertise combined with a global network
- Tailored solutions to mitigate risks and capture opportunities
- Advanced data analysis and streamlined processes for efficient compliance
We ensure your organisation is prepared, compliant, and in control of the financial impact.
Get ready for OECD Pillar Two
Complying with these new rules requires strategic planning and expert guidance. With RSM as your partner, you benefit from local expertise and international reach. We help you understand the impact, adapt your systems, and optimise your tax position.
