Pillar Two

Pillar Two is here to stay. Multinational groups and, within the EU, large domestic groups are now subject to the OECD Pillar Two rules in the jurisdictions where they operate. These rules are designed to establish a global minimum tax rate of 15% and introduce new data, reporting and filing requirements.

The legislation is highly technical. It includes detailed GloBE calculations, temporary and permanent safe harbours, anti-abuse provisions and extensive guidance that often includes additional rules that do not follow from the wording of the law itself. Combined with differences in local implementation and interpretation, this creates a challenging regulatory environment.

For most organizations, however, the real challenge is practical implementation: gathering the right data from different teams and multiple systems, aligning tax and finance on definitions and input, explaining positions to management and auditors, and setting up a process that works consistently year after year.

Svalner Atlas Advisors helps organizations make Pillar Two compliance practical and manageable, whether you are a large group with dedicated resources or a smaller team handling this alongside other priorities. As an independent tax advisory firm, we combine deep local expertise with an international perspective. We don’t start with the rulebook – we start with your business. By understanding how value is created, how reporting flows operate and how decisions are made, we translate complex regulations into clear, workable steps that fit your organization.

There is no one-size-fits-all solution to Pillar Two – but there is a solution for every organization. Some groups rely on sophisticated systems and specialist teams; others work with lean tax teams and smart templates. Both can be compliant and efficient when the approach is aligned with the organization.

Our specialists combine deep technical knowledge with hands-on implementation experience. We don’t just help you comply with Pillar Two – we help you build processes that make sense for your business and can be clearly explained to management, auditors and tax authorities.

We support organizations across the full Pillar Two lifecycle, from initial assessment to ongoing compliance.

Getting started: scope and impact

• Scoping analysis: are you within the scope of Pillar Two, which entities form part of your Pillar Two group, and which entities have a specific role for Pillar Two purposes?
• Impact assessment: where and how might Pillar Two affect your organization?
• Data readiness review: what data is required, where is it located and how can it be extracted efficiently?
• Process gap analysis: which processes need to be established or improved?

Technical Pillar Two compliance and reporting

• GloBE effective tax rate calculations on a jurisdictional basis
• Application of transitional safe harbour rules
• Assessment of permanent safe harbours and simplification measures
• Preparation and filing of the GloBE Information Return (GIR) and notifications
• Support with local filings (QDMTT, IIR and UTPR)
• Assistance with registration and notification requirements across jurisdictions

Building sustainable processes

• Design and implementation of Pillar Two compliance processes
• Building governance frameworks aligned with your organization
• Documentation of technical positions and internal guidance
• Support with financial reporting and IAS 12 disclosures
• Audit support and assistance with tax authority enquirie