BEPS Pillar Two

BEPS Pillar Two is the OECD-coordinated framework that introduces a global minimum effective corporate tax rate of 15% for multinational enterprises with consolidated revenues above EUR 750 million. It is being implemented progressively across major jurisdictions from 2024 onward.

While Pillar Two was designed for multinational corporations, its rules can affect family-office structures with substantial operating-business interests, large investment vehicles, or holding companies that meet the consolidated-revenue threshold. The Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) interact with traditional planning techniques in ways that require explicit modelling.

Family offices managing capital from operating-company ownership should review their structures against Pillar Two now. The interaction with national qualified domestic minimum top-up taxes (QDMTTs) and with traditional treaty benefits creates planning complexity that even sophisticated advisors are still working through.