Use this button to switch between dark and light mode.

Pillar Two: 5 smart ways to get ahead of the June deadline

28 August 2025

With the OECD Pillar Two rules now live in many jurisdictions and first Globe Information Returns due mid-year, June marks a critical moment for UK-based multinationals. The risks of missed safe harbours, flawed disclosures or inconsistent data are high but avoidable.

Here’s some of the key insights from the Tolley webinar “Pillar Two Reform: UK and Global Impact” hosted by Moniza Syeda with expert panellists Ross Robertson (BDO LLP), Jordan Gill (Alvarez & Marsal), and Raffaele Russo (Chiomenti Law Firm).

1. Harness your CbCR data

“The CbCR is now a central cog in the compliance process,” said Ross Robertson, Partner at BDO LLP. “Groups have had to go back to basics and refine how that report is built to make it fit for safe harbour qualification.”

Transitional CbCR safe harbours (TCSH) can materially reduce compliance burdens, but only if your Country-by-Country Report qualifies. Now’s the time to:

  • Perform the three tests to check if the TCSH is available to you
  • Extract the right data points out of your CbC reports
  • Ensure you get timings right for the election to use TCSH

Fail this, and you'll face full Globe calculations in all jurisdictions concerned.

2. Finalise your tech and data integration

“Technology can’t think it needs structured, accurate data and technical analysis done upfront,” Robertson emphasised.

Your tech stack must now be capable of:

  • Pulling reliable entity-level data across jurisdictions
  • Feeding standardised, Pillar Two-ready formats into reporting tools
  • Including non-material subsidiaries, often missed but still relevant

“If you break the safe harbour in Year 1, you lose it for all three years. The stakes are high.” – Ross Robertson, BDO LLP

3. Update governance around tax disclosures

Top-up tax will be visible in financial statements and scrutinised by auditors and tax authorities. In-house teams must work closely with finance:

  • Review Pillar Two financial disclosures now qualitative and quantitative
  • Align deferred tax reporting with the mandatory exception rules
  • Prepare for audit queries on safe harbour reliance

Pillar Two: Overview and Details of the UK’s Domestic and Multinational Top-Up Tax Provisions Effective from 31 December 2023

4. Reassess materiality and train local teams

Smaller subsidiaries still carry big compliance responsibilities. Jordan Gill, Director at Alvarez & Marsal, highlighted that “in many jurisdictions, tax is a new concept, data extraction is difficult, and technical expertise is limited.”

Action steps:

  • Don’t rely on group materiality thresholds. Assess each jurisdiction's compliance risk
  • Provide tax packs with clear inputs and definitions
  • Train subsidiaries on effective tax rate calculations and common triggers

“Groups must not overburden subsidiaries, but they do need consistent, quality input from them.” – Jordan Gill, Alvarez & Marsal

5. Plan now for FY24 reporting

June may close off FY23, but UTPR rules and new domestic minimum top-up taxes (QDMTTs) will escalate in FY24. Compliance will get more complex.

Smart in-house teams are:

  • Establishing a multi-year Pillar Two roadmap
  • Evaluating insourcing vs outsourcing for reporting
  • Building tech capability and people resource in tandem

Raffaele Russo, Partner at Chiomenti, noted: “The complexity of full Globe calculations, especially where safe harbours don’t apply, really calls into question whether your tax and accounting teams are equipped to work seamlessly.”

Act early. Avoid surprises. Protect your safe harbour.

Use Tolley+ tools to validate your CbCR, automate Globe Information Returns, and manage your compliance workflow.

Watch the full webinar here