Action Plan for CFOs: How to Get Ready for Global Minimum Tax Implementation

BEPS, Pillar Two, and Global Minimum Tax

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, substance, transfer pricing, and global governance.

For CFOs, the question is no longer “What is Pillar Two?” but rather:
“How do we operationalize it efficiently, accurately, and without disrupting the business?”

This article outlines a clear, CFO-focused action plan to prepare organizations for full Pillar Two compliance.

1. Understand Your Exposure — Start with a Pillar Two Readiness Assessment

The first step for any CFO is to assess:

  • Which jurisdictions fall below the 15% ETR

  • Whether the group exceeds the €750M consolidated revenue threshold

  • The availability of GloBE-ready data

  • The presence of deferred tax timing differences

  • Exposure to top-up tax in investment hubs, free zones, and low-tax jurisdictions

Key Output:

A heatmap of exposure showing:

  • High-risk jurisdictions

  • Medium-risk jurisdictions

  • Jurisdictions requiring minimal action

This becomes the foundation of your implementation plan.

2. Build a Pillar Two Data Model — The CFO’s New Requirement

Pillar Two is data-driven.
CFOs must ensure the organization can produce complete, consistent, and verified data for:

  • GloBE income (based on financial accounting, not tax books)

  • Covered taxes

  • Deferred tax adjustments

  • Substance-based carve-outs

  • Tax incentives and timing differences

  • Employee and asset data at jurisdiction level

Most ERP systems do not produce this today — upgrades and integrations will be needed.

3. Strengthen Collaboration Between Tax, Finance, IT, and Legal

Pillar Two compliance cannot be handled by the tax department alone.
CFOs must implement a cross-functional governance model:

  • Finance → data owner

  • Tax → technical interpretation and calculations

  • IT → system integration and automation

  • Legal → entity structure and intercompany agreements

  • HR → payroll and substance data

The CFO’s role is to ensure alignment and accountability across all teams.

4. Upgrade Transfer Pricing Policies to Pillar Two-Aligned Models

Pillar Two will expose weak or outdated transfer pricing policies.

CFOs should ensure:

  • Intercompany service pricing reflects real substance

  • IP and royalty structures are aligned with value creation

  • Financing arrangements withstand ETR impact

  • Policies are defensible in high-tax and low-tax markets

  • TP documentation (Master File, Local File) is consistent with GloBE outcomes

This is critical because TP adjustments directly affect ETR and top-up tax.

5. Prepare for Technology Transformation

CFOs must invest in:

  • Pillar Two reporting modules

  • Tax data warehouses

  • Automated ETR calculation engines

  • Consolidation system upgrades

  • Workflow automation for documentation

Manual spreadsheets will simply not sustain compliance.

Leading companies are already adopting dedicated Pillar Two tools.

6. Revisit Corporate Structure — Especially Free Zones and Low-Tax Jurisdictions

CFOs must reassess:

  • Free-zone entities

  • Principal structures

  • IP holding companies

  • Service centers

  • Investment hubs

Pillar Two may create top-up tax even where local tax is 0%.
Substance-based carve-outs can reduce exposure — but only if substance is real.

Some restructuring may be needed to optimize tax efficiency.

7. Establish a Clear Reporting and Audit Strategy

CFOs should prepare for:

  • New audit types based on GloBE mismatches

  • Increased scrutiny in low-tax jurisdictions

  • Mandatory reconciliations between accounting and GloBE results

  • Multiple layers of tax reporting

  • Coordination with external auditors

CFO leadership will be necessary to implement robust governance and controls.

8. Communicate with the Board and Key Stakeholders

The Global Minimum Tax affects:

  • Cash taxes

  • Profitability

  • Forecasting

  • Investment decisions

  • Governance and compliance

CFOs must present clear, data-backed insights so the Board understands financial impact, risks, and readiness.

Conclusion

Pillar Two is not just a tax reform it is a business-wide transformation.
CFOs who take the lead now will:

  • Reduce risk

  • Strengthen compliance

  • Improve transparency

  • Support strategic decision-making

  • Protect profitability

  • Position the organization for successful global operations

The companies that act early will turn Pillar Two from a challenge into a competitive advantage.

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