Market Taxation Analyzer Pillar Two
Your optimal preparation for the global minimum tax
Simulation of the global minimum taxation according to Pillar Two
As part of the OECD BEPS project launched in 2015, the global minimum taxation of internationally active groups of companies ("Pillar Two") has become the focus of attention. The regulations on global minimum taxation are to be applied in Germany from 2024. They are intended to ensure that in inbound and outbound cases, low-taxed subsidiaries or permanent establishments are taxed at least at group level with a minimum tax rate of 15%.
Your benefits
Simulation of the global minimum taxation according to Pillar Two
Simulate the global minimum tax for your company in different scenarios and understand the impact of OECD Pillar Two
Optimal preparation for the global minimum tax
Benefit from a high usability of the tool and get a response assessment for future challenges
The simulation with MARTA takes place in two phases
With our solution, you can manage the tax complexity of this new regulation and qualitatively assess what effect the planned taxation regime will have on your tax payment position.
01Phase 1
- Country selection: Selection of countries potentially affected by Pillar Two based on Country-by-Country Reporting (CbCR).
- Alteryx & Power BI: Processing of the CbCR data from an Alteryx flow and visualisation via Power BI for which countries a detailed assessment is useful.
- Discussion: Joint evaluation of the results from phase 1 and selection of the countries for the detailed calculation
Pricing
Market Taxation Analyzer (MARTA) – Pillar Two
- Evaluation of the Excel templates
- Online access to the MARTA tool
- Forecasting the potential impact of different scenarios
- Discuss the impact on your business
FAQ
What is the OECD BEPS 2.0 project about?
Pillar 1 establishes a new profit allocation rule for internationally operating groups that goes beyond the arm's length principle: according to this, profit is allocated regardless of the local physical presence, so that digital business models are also covered. Pillar 2 introduces a global minimum taxation to ensure a uniform minimum level of taxation.
In the context of Pillar One this means:
- Amount A: taxation right of the market/user states on the group-wide residual profit (predefined standard rates for the accrual of the non-routine profit as well as the Amount A share).
- Amount B: Size- and sector-independent standardised remuneration for so-called "baseline" marketing and sales activities.
In the context of Pillar Two this means:
- The introduction of a global minimum tax (GloBE, also known as Pillar Two) aims to limit tax competition between countries and minimise remaining Base Erosion and Profit Shifting (BEPS) risks.
- The minimum taxation is to be enforced primarily by means of the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR). The IIR is a highly simplified form of income taxation modified to achieve the minimum taxation.
How do Pillar One and Pillar Two interact?
Due to the currently discussed high thresholds for Pillar One, the majority of large international corporate groups are likely to fall under Pillar Two only. For the others: For the GloBE calculation in Pillar Two, the possible adjustment amount from Pillar One is required.