The era of 'tax-haven' strategies is coming to an end. With over 130 countries agreeing to a 15% global minimum tax (Pillar Two), multinationals must rethink how they structure their global profits.
Impact on Subsidaries
Low-tax jurisdictions will no longer provide the same advantages as before, as 'top-up' taxes will likely be applied in the home country. The focus for expansion is shifting toward operational efficiency rather than tax arbitrage.
Compliance Burden
Pillar Two brings a massive new reporting requirement. Even if you are already paying 15%, you must prove it using a complex new set of calculations. Early preparation is essential.