Pillar Two - Top 10 areas to watch for in 2025

2025 is set to be a year in which Pillar Two becomes ever more ‘real’, with a second ‘wave’ of jurisdictions placing their Pillar Two rules into effect.

Five months into 2025, many Multinational Enterprises (MNEs) have their Pillar Two preparations well underway, while others are still engaged with preliminary efforts. Jurisdictions representing a third of global GDP have had Pillar Two rules (Income Inclusion Rule (IIR) and Qualified Domestic Minimum Top-Up Tax (QDMTT)) in effect already for fiscal year 2024, as part of a first 'wave', so Pillar Two tax has already 'bitten'. That being said, aspects of the rules remain to be clarified, and...

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Authors: Grant Wardell-Johnson

Published Date: 19 May 2025