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Pillar One & Pillar Two

Pillar One & Pillar Two

Building on years of international efforts to adapt tax rules to an increasingly digitalised economy, the OECD/G20 Inclusive Framework has reshaped the global tax landscape through its two pillar solution.

As part hereof, the OECD/ Inclusive Framework released the Pillar Two Rules at the end of December 2021, resulting in a 15% minimum tax rate for in-scope (multinational) groups in all jurisdictions where they have presence as early as of financial years 2024. These rules are by now introduced in many jurisdictions, imposing a global minimum tax and significantly expanding compliance and reporting obligations for (multinational) groups.

While the OECD has finalised the technical framework for Pillar One, implementation of Amount A remains uncertain due to the absence of global consensus. Amount B, by contrast, is incorporated in the OECD Transfer Pricing Guidelines and can be applied by jurisdictions to determine a return on sales for in-scope distributors.

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.

Doc­u­men­ta­tion

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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