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OECD Pillar Two: How U.S. MNEs Can Prepare for Global Compliance

OECD Pillar Two: How U.S. MNEs Can Prepare for Global Compliance

As multinational enterprises (MNEs) navigate an ever-evolving tax landscape, the Organization for Economic Co-operation and Development (OECD’s) Pillar Two model rules represent a significant shift in global tax compliance.

While the U.S. has yet to adopt Pillar Two, its impact is already being felt by businesses operating internationally. Tax leaders must take proactive steps to prepare for these rules, which introduce a global minimum tax and new reporting requirements.

 

Understanding the Challenge
The OECD’s Pillar Two rules present a compliance challenge for U.S.-based MNEs and companies on a growth trajectory. Meeting these requirements involves addressing global anti-base erosion (GloBE) calculations, adhering to jurisdiction-specific reporting standards, and managing a vast amount of financial data across regions.

Recent surveys indicate that 87% of tax leaders identify Pillar Two compliance as a pressing concern. Organizations must act now to adjust their compliance strategies, implement new technologies, and train their teams to navigate these complex international tax requirements effectively.

 

Enhancing Compliance Procedures
To comply with Pillar Two, businesses must establish robust processes for collecting, analyzing, and sharing financial data. This data must come from multiple departments and regions, each with its own reporting requirements. For example, U.S.-based MNEs face unique challenges as they juggle compliance with the Inflation Reduction Act’s corporate alternative minimum tax (CAMT), global intangible low-taxed income (GILTI) tax, and international Pillar Two rules in regions such as the U.K. and Europe.

A strong compliance process involves creating a centralized data warehouse to standardize financial data and enable seamless collaboration. Governance measures should be put in place to ensure data integrity and accountability across the organization. Additionally, implementing automation for downstream calculations and reporting will streamline operations and reduce errors.

 

Leveraging Advanced Tax Technologies
Given the complexity of GloBE calculations, manual processes are insufficient. Businesses should adopt advanced tax technology platforms to manage large volumes of data, execute calculations, and ensure compliance with Pillar Two requirements. Automation is key to managing these demands effectively.

Research shows that tax leaders prioritizing automation, referred to as “Tax Strategists,” are better prepared for Pillar Two compliance. Investing in tax compliance software, financial process automation tools, and international tax platforms is critical.

Organizations should also prioritize training their teams on these technologies to maximize their return on investment and achieve compliance efficiently.

 

Building the Tax Team of the Future
As compliance demands grow, investing in team training and upskilling has become essential. Tax teams need to master new technologies, data management practices, and proper internal control structures to meet Pillar Two requirements.

Surveys reveal that over half of tax leaders are increasing training budgets in 2024, with many turning to outsourcing or co-sourcing to address skill gaps. This approach provides access to specialized expertise while enabling internal teams to focus on strategic initiatives.

 

Planning for Long-Term Compliance
The cost of noncompliance can be significant, both financially and reputationally. Proactive planning for Pillar Two compliance—including investments in technology, process development, and team training—will position organizations for long-term success.

For businesses facing these challenges, engaging external advisors can provide much-needed guidance. Expert support helps companies navigate evolving regulations and implement strategies that ensure compliance with OECD Pillar Two and other international tax requirements.

 

How WEI, WEI & CO., LLP Can Help
Navigating the complexities of tax compliance requires specialized knowledge and a forward-looking approach. At WEI, WEI & CO., LLP, our experts are here to guide your organization every step of the way.

Visit our Tax Services page to learn more about how we can help your business manage tax challenges with confidence.

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