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The OECD's Pillar Two rules impose a 15% global minimum tax on multinational groups with consolidated revenue above €750 million, through the Income Inclusion Rule, the Under-Taxed Profits Rule and domestic top-up taxes now live in many jurisdictions.
Why it matters for India
Indian-parented groups and Indian subsidiaries of foreign groups within the threshold must compute a GloBE effective tax rate for each jurisdiction, identify low-taxed profits, and prepare the GloBE Information Return. India's own incentives (e.g. concessional regimes) can create unexpected top-up exposure.
First steps
- Scope: confirm whether the group crosses the €750m threshold in two of the last four years.
- Data: map the data needed for the ETR computation — many groups lack it in their current systems.
- Modelling: run a jurisdiction-by-jurisdiction ETR model and identify top-up risk.
Sample alert. Pillar Two implementation dates and safe harbours vary by jurisdiction — verify before acting.
Pillar 2GloBEBEPSMinimum Tax