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BEPS 2.0: Pillar Two

KPMG insights about the impact of the Pillar Two—global minimum tax rules—and how companies are responding

The OECD/G20 Inclusive Framework on BEPS reached agreement on the Pillar Two global minimum tax rules in October 2021, putting out model rules in December 2021, commentary in March 2022, and further administrative guidance in February 2023. These new Global Anti-Base Erosion (GloBE) rules are now being implemented by jurisdictions around the world and will apply to many companies from 2024. Multinational companies need to stay abreast of these developments to navigate and prepare successfully for the changes in the global tax landscape.

You'll find insights from KPMG about these developments on this page.

BEPS Pillar Two 2024 quarterly reporting is fast approaching

The time to prepare is now

KPMG has developed an innovative approach to Pillar Two readiness that helps enable companies to comply with reporting requirements in both the near and long term.

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Featured content

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Chief Tax Officer Insights

Chief Tax Officer (CTO) Insights is designed to highlight top-of-mind issues for tax executives and ways CTOs are addressing these opportunities and challenges. Each edition covers critical information CTOs can leverage to further their organization's tax function.

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Dive into our thinking:

BEPS 2.0 State of Play Summary

High-level overview of administrative and legislative developments in jurisdictions around the world related to the implementation of Pillar Two

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KPMG BEPS 2.0 Automation Technology

Modeling for the changing global tax landscape – Learn more about the multiplatform tool that allows for both high-level and detailed modeling of BEPS 2.0 Pillar Two provisions, including safe harbor calculations.

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BEPS developments from KPMG TaxNewsFlash

TaxNewsFlash-BEPS | Access all alerts

KPMG Pillar Two webcasts

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April 18, 2024 | Finance’s role in Pillar Two Enablement

Join the Finance’s role in Pillar Two Enablement webcast hosted by KPMG.

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February 28, 2024 | Pillar Two: Frequently Asked Questions (Part Two)

KPMG professionals share insights on frequently asked questions about implementing Pillar Two covering tax, accounting and audit topics.

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Webcast: Pillar Two: Frequently asked questions
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January 24, 2024 | Pillar Two: Frequently Asked Questions (Part One)

KPMG professionals share insights on frequently asked questions about implementing Pillar Two covering tax, accounting and audit topics.

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August 8, 2023 | New Pillar Two Guidance: Practical Impact on MNEs with U.S. Operations

This webcast examines BEPS Pillar Two guidance, released by the OECD on July 17, and the potential impact on multinational enterprises with operations in the United States.

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Pillar Two Gameplan

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Pillar Two Gameplan – Executive summary

Our executive guide to the new rules – with implementation steps, and how accounting and finance may be impacted.

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Pillar Two pregame show - Episode 5
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Pillar Two pregame show - Episode 5

Playing the long game: Strategizing for the future effects of Pillar Two.

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Pillar Two pregame show - Episode 4
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Pillar Two pregame show - Episode 4

Officiating the Rules: Navigating the accounting and audit considerations.

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Pillar Two pregame show - Episode 3
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Pillar Two pregame show - Episode 3

Going the distance: Diving deep into the Globe ETR calculation and its many challenges.

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Pillar Two Pregame Show: Episode Two

Simplifying the game - Getting to know the safe harbor

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Pillar Two Pregame Show: Episode One

Blocking and tackling: Understanding the fundamentals of Pillar Two

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KPMG TaxRadio podcasts
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March 7, 2024 | Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations

Inside International Tax: What can taxpayers do today to be ready for the expected finalization of the section 987 regulations?
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February 08, 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

What guidance does Notice 2023-80 give regarding the interaction of GloBE rules with foreign tax credits and dual consolidated losses?

February 08 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
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October 4, 2023 | Pillar Two Reloaded: Second Round of OECD Guidance

Podcast: What guidance was released in the second round of OECD Pillar Two guidance and where do we stand on the implementation of GloBE rules?

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June 30, 2023 | P2 and Congress: It’s Complicated

Podcast on legislative negotiations in Washington and how the divided Congress could come to terms with Pillar Two
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June 28, 2023 | Ready, Set, GloBE!

Podcast: How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
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March 29, 2023 | I Literally CAMT: Dealing with Your International Min Tax Issues

Podcast: What are the most pressing CAMT international tax issues for which taxpayers need guidance today?
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February 1, 2023 | What to Expect when You’re Expecting Pillar Two

Podcast discusses when U.S. multinationals can expect the GloBE rules to come on line and how those rules may impact them
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October 5, 2022 | A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

Podcast: What GloBE rules should you consider in structuring M&A transactions today?

    KPMG reports and articles

    Recent DCL and Pillar 2 Guidance: Comments and Recommendations

    Recent DCL and Pillar 2 Guidance: Comments and Recommendations
    Leveling the Pillar Two Playing Field for the Asset Management Industry

    Leveling the Pillar Two Playing Field for the Asset Management Industry
    Pillar Two Implications of U.S. Self-Initiated Transfer Pricing True-Ups

    Pillar Two Implications of U.S. Self-Initiated Transfer Pricing True-Ups
    Foreign Tax Credits for Multinationals Involve a Winding Path

    Foreign Tax Credits for Multinationals Involve a Winding Path
    Transfer Pricing Implications of Pillar Two Minimum Tax Rules

    Transfer Pricing Implications of Pillar Two Minimum Tax Rules
    Pillar Two Watch Out: Is There a U.S. Sandwich in Your Structure?

    Pillar Two Watch Out: Is There a U.S. Sandwich in Your Structure?
    Gearing up for Pillar Two Operational Readiness

    Gearing up for Pillar Two Operational Readiness
    Despite Relief, Pillar Two Problem Remains for US Multinationals

    Despite Relief, Pillar Two Problem Remains for US Multinationals
    Pillar Two: Subject to Tax Rule

    Pillar Two: Subject to Tax Rule
    Pillar Two: GloBe Information Return

    Pillar Two: GloBe Information Return
    Global Minimum Tax

    Global Minimum Tax
    Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

    Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)
    Stronger Case for Stock Based Compensation Recharges under OECD Pillar Two

    Stronger Case for Stock Based Compensation Recharges under OECD Pillar Two

    KPMG International Tax videos

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    Pillar Two Challenges: Book Accounting and GloBE Income Calculation

    International Tax Team video series – Overview of the book accounting considerations when calculating GloBE income under Pillar Two (part 4)

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    Pillar Two Challenges: Data Gaps, Technology Needs, and Modeling

    International Tax Team video series – Overview of the implementation challenges that the OECD’s Pillar Two presents beyond the tax technical (part 3)

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    Pillar Two Implementation: U.S. Multinationals Impacts and Considerations
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    Pillar Two Implementation: U.S. Multinationals Impacts and Considerations

    International Tax Team video series – Overview of the impact of the OECD’s Pillar Two initiative on U.S. multinational groups (part 1)

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    Related insights and resources

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    Taxation of the Digitalized Economy: Developments Summary

    Overview of how countries are responding to the challenges arising from the digitalized economy

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    Global Tax Reform
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    Global Tax Reform

    BEPS and Tax Transparency: Insights on the drivers of global tax reform affecting multinational companies

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    Be ready for disruption - tax insights

    Tax insights and analysis to help organizations respond with speed and confidence

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    Modeling a World of Tax

    The far reaching power of KPMG tax models. 

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    Helping multinational organizations succeed in the current complex international tax environment. 

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    Advising on the constantly evolving tax laws, regulations, and economic pricing methods. 

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    Tax Controversy & Dispute Resolution Services

    A coordinated approach to tax controversary multinationals. 

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    Meet our team

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    Danielle E. Rolfes
    Partner in Charge, Washington National Tax, KPMG US
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    Kevin Brogan
    Principal, International Tax, Washington National Tax, KPMG US
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    Quyen Huynh
    Principal, International Tax, Washington National Tax, KPMG US
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    Marcus Heyland
    Principal, Washington National Tax, KPMG US
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    Alistair Pepper
    Managing Director, Economic & Valuation Services, Washington National Tax, KPMG U.S. Tax Services (London) LLP
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    Image of Danielle E. Rolfes
    Danielle E. Rolfes
    Partner in Charge, Washington National Tax, KPMG US
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    Image of Kevin Brogan
    Kevin Brogan
    Principal, International Tax, Washington National Tax, KPMG US
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    Image of Quyen Huynh
    Quyen Huynh
    Principal, International Tax, Washington National Tax, KPMG US
    Read bio
    Image of Marcus Heyland
    Marcus Heyland
    Principal, Washington National Tax, KPMG US
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    Image of Alistair Pepper
    Alistair Pepper
    Managing Director, Economic & Valuation Services, Washington National Tax, KPMG U.S. Tax Services (London) LLP
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