Introduction With the OECD’s Pillar Two Global Minimum Tax (GMT) moving from policy discussion to on-the-ground implementation, CFOs across the world especially in MENA, Europe, Africa, and Asia are facing one of the biggest tax transformations in decades. The Global Minimum Tax introduces a jurisdiction-based 15% effective tax rate (ETR), requiring unprecedented visibility into data,

Introduction With the introduction of the OECD’s Global Minimum Tax (Pillar Two), multinational enterprises (MNEs) face significant changes in how jurisdictions tax their income. One of the most important features designed to soften the impact of the minimum tax is the Substance-Based Income Exclusion, commonly referred to as the Substance-Based Carve-Out. This mechanism ensures that

Introduction Over the past decade, transparency has become one of the core pillars of international tax policy. As part of the OECD’s BEPS Action 13, Country-by-Country Reporting (CbCR) has emerged as one of the most powerful tools used by tax authorities to understand how multinational enterprises (MNEs) allocate income, taxes, functions, and employees across jurisdictions.

Introduction The OECD’s Pillar Two framework introduces a Global Minimum Tax (GMT) of 15%, calculated on a jurisdiction-by-jurisdiction basis.The heart of the Pillar Two system is the Effective Tax Rate (ETR) computation, which determines whether an MNE must pay a top-up tax in any country where its ETR falls below 15%. Understanding ETR under Pillar

Introduction The OECD’s BEPS 2.0 project introduces two major pillars Pillar One and Pillar Two designed to modernize global taxation in a digitalized world.However, for most multinationals, the two pillars feel like a maze of formulas, thresholds, and overlapping rules. This article breaks down Pillar One vs Pillar Two in a simple, practical way, highlighting

Introduction In today’s international tax environment, Transfer Pricing (TP) and the BEPS (Base Erosion and Profit Shifting) project have become two of the most influential forces shaping the global tax landscape. For multinational enterprises (MNEs), understanding how these frameworks interconnect is essential for building sustainable, compliant, and tax-efficient global structures. BEPS and Transfer Pricing are