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Implementing Pillar One & Pillar Two

Implementing Pillar One & Pillar Two

Building upon work conducted for several years on how to adapt the international tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework proposes a two-pillar overhaul of the existing system as from 2023/2024. While the main policy features are agreed, detailed model rules and draft multilateral conventions are due to be released over 2022.

Tax directors and their teams can already model the impact, prepare for the additional tax compliance burden and assess opportunities for manageable restructurings to mitigate the increased complexity.


Belgium implemented the Pillar Two rules at the end of last year via publication of the Law of 19 December 2023 (Belgian Pillar Two Law). The Pillar Two rules entered into force on 31 December 2023 and apply to Fiscal Years starting on or after 31 De

How we can help

With our integrated tax & legal expertise and comprehensive transfer pricing knowledge we advise businesses in our main service areas Documentation, Planning & Strategy and Dispute Resolution.


Often we hear that tax departments face issues in dealing with new transfer pricing documentation requirements such as Master File, Local File and Country-by-Country Reporting obligations. Our transfer pricing specialists help you to assess your documentation against stringent new requirements in our home markets (Netherlands, Belgium, Switzerland and Luxembourg). These experiences are used by our clients to roll out solid documentation standards in other jurisdictions. Our approach allows us to have a global impact with our local reach.

Plan­ning & Strat­e­gy

Feedback from clients shows that new regulatory developments force businesses to review their legal structures. We help your tax department in formulating sustainable transfer pricing strategies that are in line with your business whilst maintaining tax efficiency. Clients ask our advice on transfer pricing policies, building and converting business models and profit allocations into permanent establishments.

Dis­pute Res­o­lu­tion

Clients experience the process of avoiding double taxation as very lengthy and complicated. With our integrated tax & transfer pricing practice, we are able to help you accelerate procedures and prevent double taxation. We also regularly assist our clients with audits and resolve (international) transfer pricing disputes both at an administrative and court level.

Organisations operating in Europe must keep abreast of EU tax law developments. Our team monitors developments and keeps you informed.
When advising your company on state aid matters, we pull together our competition law experts and tax/transfer pricing specialists to best service your requirements.
We offer integrated services, in collaboration with both our attorneys-at-law and civil-law notaries.
Tax compliance is about more than submitting an accurate tax return on time.

What others say

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In the Netherlands, Luxembourg, Switzerland, and Belgium we received tier-1 rankings.
International Tax Review (2023)
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