Tax challenges arising from the digitalisation of the economy
The Organisation for Economic Cooperation and Development (OECD) is working full steam on the two-pillar solution of the Base Erosion and Profit Shifting (BEPS) 2.0 project. Multinational enterprises across industries are likely to be affected. Check out the latest developments and PwC insights to get prepared for the new tax era.
“BEPS 2.0 has brought groundbreaking changes to the international tax landscape. Multinational enterprises should take immediate actions to assess the potential impact on their business models and global tax liabilities, as well as to get themselves prepared for the additional tax compliance and reporting requirements.”
Pillar One
Consolidated report on Amount B
The OECD released a consolidated report on Amount B (link) which incorporates all relevant materials published throughout 2024.
24 February 2025
Multilateral convention to implement Amount A
An overview of the multilateral convention released by the OECD on 11 October 2023 to implement Amount A
31 October 2023
Pillar Two
OECD releases additional Pillar Two guidance under BEPS 2.0
On 15 January 2025, the OECD released additional GloBE administrative guidance and several related documents aimed at streamlining the administration of the global minimum tax, such as a list of the jurisdictions with transitional qualified status, an updated GloBE information return and related commentary, and a multilateral competent authority agreement to facilitate central filing and exchange of the GloBE information return.
Hong Kong’s bill on implementation of global minimum tax and Hong Kong minimum top-up tax gazetted
Following the consultation outcome published in October 2024, a bill was gazetted in Hong Kong on 27 December 2024 to implement the GloBE rules, which comprises the IIR and UTPR, as well as the Hong Kong minimum top-up tax.
31 December 2024
Pillar Two Readiness Guide for Asia Pacific Multinational Enterprises
The Pillar Two Readiness Guide is designed to help in-scope MNEs evaluate preparedness for Pillar Two, navigate unique complexities, identify any actions to undertake to sustain compliance requirements, and understand possible financial and operational implications of Pillar Two on existing business models. This guide outlines technical areas that will help MNEs refine their strategies for the 2024 full-year reporting and, ultimately, prepare for the first GloBE return filings in 2026.
Consultation outcome on implementation of global minimum tax and Hong Kong minimum top-up tax released
On 30 October 2024, the HKSAR Government released the consultation outcome on the implementation of the global minimum tax and the Hong Kong minimum top-up tax. We are pleased that the Government has carefully considered the constructive comments provided by various stakeholders including PwC, and thoroughly consulted the OECD. An amendment bill is expected to be introduced in January 2025.
Nine jurisdictions sign STTR Multilateral Instrument
The OECD hosted a signing ceremony for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR Multilateral Instrument) on 19 September 2024, during which nine jurisdictions signed the STTR Multilateral Instrument and ten other jurisdictions expressed their intent to sign.
20 September 2024
How PwC can help your company with Pillar Two
PwC can help you assess and model the likely financial and operational consequences of Pillar Two. Please click here to learn more and feel free to get in touch with our tax professionals below.
To understand the status of Pillar Two implementation in different jurisdictions, please visit PwC's Pillar Two Country Tracker.
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