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BEPS Pillar II - Global Minimum Taxation

We are at a turning point where international efforts to curb tax avoidance practices are crystallizing into tangible regulations. With the anticipated implementation of BEPS Pillar II in 2024, which mandates a global minimum tax of 15% for large multinational corporations, a new era of corporate taxation is emerging. This marks a critical phase in the global fight against tax evasion and avoidance, reflecting the growing ambition of international organizations to promote fairness and transparency in the global tax system.


Problem Solver

BEPS Pillar II, a crucial component of the Two-Pillar Approach developed by the OECD, is a strategic framework aimed at reforming global corporate taxation. The Global Minimum Taxation for multinational corporations is the cornerstone of Pillar II, designed to curb the practice of profit shifting to low-tax countries.

This initiative reflects a growing international effort to promote tax fairness and combat aggressive tax avoidance strategies, ensuring a fair and transparent global economic system.


BEPS Pillar II aims to close a critical gap in the international tax system: the practice of Base Erosion and Profit Shifting (BEPS) by multinational corporations.

By introducing a global minimum tax rate of 15% for large corporations, Pillar II addresses these systemic weaknesses by offering less incentive for multinational companies to artificially shift profits. This promotes a fairer distribution of tax burdens in line with the actual economic activities of the companies and aims to make the international tax system more resilient and equitable. The regulation strengthens the tax sovereignty of countries and contributes to stabilizing and harmonizing the international tax environment.


BEPS Pillar II is not just a regulatory requirement; it's an opportunity to rethink our approach to taxation, creating sustainable value for our clients.

Markus Noçon | 4C GROUP

Success Factors

  • Thorough Understanding of Regulations: A deep understanding of the BEPS Pillar II regulations is essential. This includes not only the basics of the global minimum tax rate but also an understanding of country-specific laws and regulations relevant to implementation.
  • Strategic Tax Planning and Restructuring: Companies need to review and possibly restructure their current tax structures to meet the requirements of Pillar II. This could involve revising business models, relocating functions, or adjusting transfer pricing policies.
  • Efficient Data Management and Analysis: Since calculating the effective tax burden and Top-Up Tax requires complex data analysis, a robust data management system is crucial. Companies must be able to efficiently collect, process, and analyze relevant data.
  • Compliance Through Specialized Knowledge: Given the complexity of the required calculations and reporting and the novel nature of Pillar II, collaboration with experts can be greatly beneficial.

In this way, companies can ensure they effectively respond to the requirements of BEPS Pillar II, minimizing risks and optimally leveraging opportunities.

We are Happy to Support you


Why 4C?

We support you in implementing the requirements of the new BEPS Pillar II regulations. Introducing the GloBE rules is not just about calculating a minimum tax; it's more about sourcing and establishing the necessary information. We are here to advise and support you on this transformation.

Quick Check

The Quick Check is designed to assess your current state regarding the applicability of these minimum taxation rules and provides you with an overview of the extent to which you already meet the requirements of the Safe Harbour Standards.


As part of a consulting project, we assist you in implementing the GloBE Information Reports - from detailed analysis to process implementation.

4C Whitepaper: BEPS Pillar II - Global Minimum Taxation

BEPS Pillar II

Please note that at the moment we can offer this document only in German. For further information please do not hesitate to contact us directly.

More Topics

Top topic

A transformation of companies is imperative.

Finance Target Operating Model (TOM)

Finance Office Evolution


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Markus Noçon

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