What is OECD Pillar One and Pillar Two?

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) recently endorsed the key components of the two-pillar approach to International Tax Law. The agreement has set an ambitious and challenging timeline for both Pillars and whatever the final rules, most global businesses of any scale are likely to be impacted.

Pillar One: Nexus and profit allocation rules
Pillar One targets the largest multinational groups focusing initially on those with at least EUR 20 billion of consolidated revenue and net profits of over 10% (i.e., profits before tax to revenue) and will require them to pay tax in the locations where their customers and users are located. A formulaic approach will be used to allocate a percentage of profits between each jurisdiction. Pillar One should effectively require in scope multinationals to pay at least some tax in the markets they interact with.

Pillar Two: Global minimum tax
Pillar Two, the key components of which are commonly referred to as the "global minimum tax" or "GloBE", introduces a minimum effective tax rate of at least 15%, calculated based on a specific ruleset. Groups with an effective tax rate below the minimum in any particular jurisdiction would be required to pay top-up tax in their head office location or in the location of other affiliates. The tax would be applied to groups with revenue of at least EUR 750 million, making it far more widely applicable than Pillar One.

What is Deloitte's OECD Pillar One and Pillar Two Tax Advisory service?

Deloitte’s OECD Pillar One and Pillar Two Tax Advisory service combines the deep expertise of Deloitte tax specialists with the analytical power of our technology solution to help companies assess and evaluate the potential implications of Pillar One and Pillar Two on their tax profile.


Covers Pillar One and Pillar Two

Calculates Amounts A and B of Pillar One and the minimum taxes imposed by the Income Inclusion Rule and the Undertaxed Payment Rule of Pillar Two.


The ability to upload data through Excel files allows for a nimble, flexible and customizable solution.

Simple inputs

Supports flexibility in the inputs, starting with country-by-country reporting (CbCR) and other easily-accessible data, and having an option to further refine the modeling with additional data.

Default selections

Default selections included for most of the Pillar One and Pillar Two assumptions based on certain public comments made by governmental agencies in various countries and by other stakeholders. Inputs may be tailored based on specific facts and circumstances.

Built-in flexibility

Due to uncertainties in the OECD proposals, our approach builds in alternative interpretations of the guidelines.

Develop scenarios

Used to identify impacts and provides insight into the different ways Pillar One and Pillar Two may unfold.

Intuitive visuals

Visualized dashboards tell the story of how the proposals may affect your tax position.


Evaluate the impact of the OECD’s Pillar One and Pillar Two proposals

Perform accurate compliance calculations post-enactment

Identify data limitations that may need to be considered for compliance

Customize to your fact pattern and data sources

How it works

Assess the impact of Pillar One and Pillar Two Image

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For more information about this tax advisory service, please download the brochure, or contact your Deloitte client service team.