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Pillar Two

The implementation of the OECD’s Pillar Two introduces complex challenges for multinational groups with consolidated revenue over €750m. PwC has a tech-enabled approach, driven by the Pillar Two Engine, to help you quickly calculate the impact of Pillar Two and develop a response that is aligned to your business strategy. Supported by a global network of international tax specialists, PwC works collaboratively to navigate complexity and power great value to assess, report and comply effectively.

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PwC Cyprus Pillar Two Webcasts

Video 04/07/24

Pillar 2: Made Simple & Practical

PwC Cyprus Pillar Two Publications

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Pillar Two Resources & Updates

EU Pillar 2 Directive

More information on EU Pillar 2 Directive

OECD Pillar 2 Materials

More information regarding OECD Pillar 2 Materials (including issued Administrative Guidance)

EU Pillar 2 Directive/Cyprus Transposition

On December 18, 2024, the Global Minimum Tax of MNE Groups and Large-Scale Domestic Groups Law (the "Law") transposing into Cyprus national law the relevant EU Directive issued on December 14, 2022, on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups was published in the Cyprus Government Gazette. Please refer to the below link for a Greek version of the Law.

Cyprus Pillar 2 Law (published in Greek)

Thought Leadership

Pillar Two Guide for EMEA MNEs

A step-by-step plan

Pillar Two Country Tracker

Check the status of implementation in different countries

Technical Guides

Podcasts

Tune in to Pillar Two episodes in the Cross- Border Tax Talks podcast to hear about the latest insights from our PwC specialistsaround the globe.

Blogs

Readiness: What’s your data strategy?
Countdown to Pillar Two: Have you completed these key actions?

How PwC Can Help

Acting as the foundation to develop an extensive data strategy, assess operational preparedness, or determine a calculation approach, PwC’s Data Input Catalog is the core to Pillar Two readiness.

The Data Input Catalog outlines the comprehensive data requirements for Pillar Two, serving as a crucial tool to identify and map the data needed for calculation and upcoming compliance obligation. This dynamic and globally governed catalog includes all necessary data for the qualified domestic minimum top-up taxes, the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR), and will contain the essential information for forms as they become available.

We have been mapping Pillar Two data for over two years and have additional explanations, hundreds of user stories and can provide insight on the practical need for each data requirement.

Access PwC's Data Input Catalog

Depending on spreadsheets to gather data, perform complex calculations, interpret analyses, and produce reports makes it challenging to keep up with the changing jurisdictional requirements and run real-time scenarios. There’s a better way.

PwC’s Pillar Two Engine is a centralised, cloud-based calculation engine for quantifying the impact of Pillar Two, including provision, compliance and modelling. The Pillar Two Engine is adapted for relevant local rules and interpretations in order to meet Pillar Two requirements for global and statutory compliance, including constituent entity analysis, Transitional Safe Harbor assessments, and IIR, UTPR, and QMDTT computations and allocations.

Built on Beacon graph technology, the Pillar Two Engine computes accurate and visually traceable results. It is based on underlying data and uses a centralised rule library that is reviewed by global tax experts.

Our proprietary, cloud-based tech can support your Pillar Two adoption.

Identifying the data requirements and developing a comprehensive data strategy should be one of your first steps in preparation for Pillar Two. You have a variety of data sources, owned by a diverse group of stakeholders which can make the collection and synthesization of the data tremendously challenging. Early cross-functional engagement is critical to ensure that you have the appropriate data and your system owners are aware of what will be required of them under Pillar Two.

We can help you develop a data strategy rooted in systems and processes that can help you sustain reporting and compliance requirements.

Tailored Solutions

Pillar Two could have widespread impact on your financial operating model requiring early stakeholder engagement and may require additional budget. To address the multitude of challenges, you must ask if your current data model, systems, technology, and processes can support the requirements introduced by this new international tax framework.

We can help you assess your operating model and processes, identify gaps and design solutions for enhanced governance and efficiency that you will need to report and comply with the dynamic Pillar Two environment.

Download an action plan - EMEA

Contact us

Stelios Violaris

Partner, Tax Advisory, International Tax Services Leader, PwC Cyprus

Tel: +357-22555300

Varnavas Nicolaou

Partner, Connected Tax Compliance Managed Services Leader, Head of Network Clients Market, PwC Cyprus

Tel: +357-22555382

Joanne Theodorides

Director, Tax Advisory, PwC Cyprus

Tel: +357-22553694

Nikolas Nikolaides

Director - Finance, Operations & Data | Data, Insights & Technology, PwC Cyprus

Tel: +357-26555105

Stavros Supashis

Director, Tax Advisory, PwC Cyprus

Tel: +357-22555555

George A Georgiou

Senior Manager, Tax Reporting & Strategy and Connected Compliance - Tax Technology, PwC Cyprus

Tel: +357-22555306

George Constantinides

Partner, Tax Advisory, PwC Cyprus

Tel: +357-22555249

© 2021 - 2025 PwC. All rights reserved. PwC refers to the Cyprus member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details.