Don’t let the global minimum tax issue label fool you – BEPS 2.0 is about far more than just tax.
The Organisation for Economic Co-operation and Development (“OECD”) launched its Base Erosion and Profit Shifting (“BEPS”) initiative in 2013 to address tax planning strategies that allowed multinational enterprises to shift profits to low-tax jurisdictions. More than a decade later, those reforms have evolved into BEPS 2.0, with Pillar Two introducing a 15% global minimum corporate tax for large multinational groups.
As the global minimum tax moves from policy into implementation, businesses are discovering that Pillar Two compliance depends on far more than technical tax expertise. It requires coordinated input from finance, legal, governance, technology, entity management, and operations.
For many multinational enterprises, the biggest challenge is no longer understanding the rules; it is bringing together the people, processes, and information needed to comply with them.
Tax may own the rules, but not the data
Calculating jurisdictional effective tax rates requires information drawn from across the business. That includes:
statutory financial data
legal entity information
ownership structures
accounting records
deferred tax information
local reporting requirements
Few of these sit entirely within the tax function. Instead, they are often owned by multiple teams operating across different jurisdictions and systems. As a result, successful compliance depends on collaboration.
Finance has a critical role
Finance teams already manage much of the financial information underpinning Pillar Two calculations. They are responsible for financial reporting, consolidations, accounting policies, and maintaining data quality.
As reporting obligations increase, finance teams will play an increasingly important role in ensuring consistent information is available across jurisdictions.
Legal and entity management are equally important
Entity structures sit at the centre of the Global Anti-Base Erosion (“GloBE”) rules. Changes to ownership, holding structures, acquisitions, and reorganisations can all affect how the rules apply.
Maintaining accurate legal entity records therefore becomes more than a governance exercise. It directly supports Pillar Two compliance.
Operations connect everything together
Operational teams often provide the coordination that allows information to move between functions. They help establish reporting timelines, define responsibilities, manage documentation, and support ongoing compliance processes. Without these operational foundations, even technically correct tax positions can become difficult to evidence consistently.
Compliance is becoming a continuous process
Implementation is continuing across multiple jurisdictions, while the OECD continues to publish additional guidance and safe harbour provisions. Domestic legislation is also evolving as countries refine their local approaches.
So, what does this mean in practice? It means that means Pillar Two is unlikely to remain a one-time implementation exercise. Instead, businesses should expect ongoing reporting, monitoring, governance, and process improvement.
Building a coordinated operating model
The businesses that adapt most effectively will not necessarily be those with the largest tax teams.
They will be those that establish clear ownership across the business. That includes:
defined governance
integrated data management
consistent reporting processes
cross-functional collaboration
ongoing regulatory monitoring
These capabilities not only support Pillar Two compliance but also strengthen broader financial governance and operational resilience.
Looking beyond compliance
The OECD's Pillar Two framework represents one of the most significant changes to international corporate taxation in decades, but its implementation also highlights a broader trend.
Regulatory frameworks increasingly depend on high-quality data, transparent governance, and coordinated operating models that span multiple business functions.
The businesses that reckon with this shift will be better prepared not only for global minimum tax requirements, but for the next generation of cross-border regulatory obligations.
Download our global minimum tax guide
Our latest eBook explains how the OECD's Pillar Two framework operates, outlines the latest implementation developments, and highlights the practical considerations multinational groups should address as the global minimum tax regime continues to evolve.
[Download the eBook]
