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, […]

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

Introduction As the OECD’s Pillar Two Global Minimum Tax (GMT) framework comes into effect, multinational enterprises (MNEs) around the world including those operating in Egypt and the wider MENA region are facing a major transformation in how they calculate, report, and manage their global tax obligations. Pillar Two introduces a 15% minimum effective tax rate

Introduction The OECD’s global tax reform especially BEPS 2.0, with its two pillars on profit reallocation and the Global Minimum Tax (GMT) – is reshaping how multinational enterprises (MNEs) are taxed worldwide. For countries in the Middle East and North Africa (MENA), this reform is more than a technical tax update. It touches on investment

Introduction The Global Minimum Tax (GMT) under OECD BEPS 2.0 Pillar Two represents one of the most significant shifts in international taxation in decades.Designed to ensure that large multinational enterprises (MNEs) pay a minimum effective tax rate (ETR) of 15% regardless of where they operate, Pillar Two will reshape tax structures across the Middle East

Introduction BEPS 2.0 represents the most transformative global tax reform since the original OECD BEPS package launched a decade ago.As we approach 2025, multinational groups in Egypt, the Middle East, and around the world must begin preparing for the practical adoption of: Pillar One Amount A (Reallocation of taxing rights) Pillar Two Global Minimum Tax