The OECD's global minimum tax framework has moved from proposal to reality, with 147 countries and jurisdictions now participating in the Inclusive Framework on BEPS.
Understanding the OECD's Pillar Two Framework
Since 2024, Pillar Two rules have taken effect across major jurisdictions including the UK, EU Member States, and Japan, bringing a 15% global minimum corporate tax rate into force for large multinational enterprises.
For fund managers and multinational groups, staying on top of these changes is no longer optional. This guide breaks down the framework's core mechanics, the compliance obligations now in effect, and the practical steps companies should take to stay ahead.
What's inside
Why the OECD introduced a global minimum tax and what problem it solves
The key milestones that brought Pillar Two from proposal to law
The framework's core mechanics, including the 15% minimum tax rate and how it applies in practice
The latest OECD administrative guidance and where it's headed
What multinational groups need to watch as compliance ramps up
