Initial preparation considerations
The steps below will help you in preparing for Pillar Two compliance. These steps are not exhaustive and do not include all matters that you must consider when understanding how the Pillar Two rules apply to you.
- Determine if the multinational enterprise (MNE) group, large-scale domestic group, or standalone entity, is in scope of the Pillar Two rules.
- Establish if any Pillar Two safe harbours or exemptions apply.
- Ascertain the applicable Pillar Two registration and return deadlines.
- Define the filing roles of the entities within the MNE group or the large-scale domestic group.
- Identify financial and tax data required for completion of the Top-up Tax Information Return (TIR).
Definition
A 'safe harbour' is a provision that eases the administrative burden on in-scope groups, particularly in the initial period of the application of the Pillar Two rules.
Revenue recommends that you maintain a register of Pillar Two entities within your group. It will assist you in identifying tax registration and filing compliance obligations for the various entity types in your group such as:
- Ultimate parent entities.
- Intermediate parent entities.
- Partially-owned parent entities.
- Constituent entities.
- Joint ventures.
- Designated local entity.
- Designated filing entity.