Exemptions under Pillar 2: Government Entities, Pension Funds and Funds

This article outlines our current understanding of the most relevant categories of excluded entities which will be refined once the commentary is issued (expected as soon as early February).

Broadly consistent with Country-by-Country reporting, Pillar Two is proposed to be applicable only to groups with revenue in excess of €750 million (AU$1.2 billion) in 2 of the last 4 years (MNE Group). The existence and membership of the MNE Group is generally based on consolidation for financial reporting purposes. In addition to this revenue threshold, certain categories of entities are specifically excluded from the scope of the GloBE rules, including ‘government entities’, ‘internation...

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Authors: Scott Farrell, Minh Dao,

Published Date: 04 February 2022