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Global minimum tax
Streamline Pillar Two adoption with PwC’s tech-enabled approach
The implementation of the Organisation for Economic Cooperation and Development (OECD)’s Pillar Two introduces complex challenges for multinational groups with consolidated revenue over €750m. In Hong Kong, the Pillar Two rules, specifically the Hong Kong Minimum Top-up Tax (HKMTT) and Income Inclusion Rule (IIR), were enacted on 6 June 2025 and took effect retrospectively from 1 January 2025, marking a significant shift in the tax landscape. As you strive to understand the magnitude and impact of Pillar Two’s 15% global minimum tax, it is important to adapt your systems, technology, processes, governance and controls to meet evolving data requirements while positioning for growth.
PwC has a tech-enabled approach, driven by the Total Tax Management Platform and Pillar Two Engine, which integrates data pipelines and a comprehensive repository of information to help you quickly calculate the impact of Pillar Two and develop a response that is aligned to your business strategy. Supported by a global network of international tax specialists, PwC works collaboratively to navigate complexity and power great value to assess, report and comply effectively.
How we can help
- Data strategy
- Data readiness
- Calculation engine
- Operational readiness
Data strategy
Identifying the data requirements and developing a comprehensive data strategy should be one of your first steps in preparation for Pillar Two. You have a variety of data sources, owned by a diverse group of stakeholders which can make the collection and synthesisation of the data tremendously challenging. Early cross-functional engagement is critical to ensure that you have the appropriate data and your system owners are aware of what will be required of them under Pillar Two.
We can help you develop a data strategy rooted in systems and processes that can help you sustain reporting and compliance requirements.
Data readiness
Acting as the foundation to develop an extensive data strategy, assess operational preparedness, or determine a calculation approach, PwC’s Total Tax Management Platform and Data Input Catalogue is the core to Pillar Two readiness.
The Data Input Catalogue outlines the comprehensive data requirements for Pillar Two, serving as a crucial tool to identify and map the data needed for calculation and upcoming compliance obligation. This dynamic and globally governed catalogue includes all necessary data for the qualified domestic minimum top-up taxes, the IIR and the Undertaxed Profits Rule (UTPR), and will contain the essential information for forms as they become available.
PwC’s Total Tax Management Platform is a mature, technology-driven system designed to prepare data for quantitative analysis and data visualisation related to Pillar Two. By leveraging this robust platform, mapped data can be automatically collected from your existing technology infrastructure—including Enterprise Resource Planning (ERP) systems, Consolidated Systems, or other source data—at any desired frequency. The platform allows for the effortless transformation and integration of collected data with the Data Input Catalogue through data pipelines, ensuring readiness for downstream consumption. With over 20 tax modules, the Total Tax Management Platform is a sophisticated solution that not only streamlines the management of complex compliance requirements but also aids in simultaneous planning for the impact of Pillar Two.
We have been mapping Pillar Two data for over two years and have additional explanations, hundreds of user stories and can provide insight on the practical need for each data requirement.
Calculation engine
Depending on spreadsheets to gather data, perform complex calculations, interpret analyses, and produce reports makes it challenging to keep up with the changing jurisdictional requirements and run real-time scenarios. There are better ways.
PwC’s Total Tax Management Platform offers a comprehensive solution that goes beyond mere data staging—it can perform Pillar Two analysis and computations tailored specifically to Hong Kong’s local rules and regulations. In addition to its capability for Hong Kong-specific calculations, the Total Tax Management Platform seamlessly integrates with Pillar Two Engine through build-in data integrator. The processed data from the Total Tax Management Platform can be exported to Pillar Two Engine for performing Pillar Two calculations on a global scale, covering all jurisdictions.
PwC’s Pillar Two Engine is a centralised, cloud-based calculation engine for quantifying the impact of Pillar Two, including provision, compliance and modelling. The Pillar Two Engine is adapted for relevant jurisdiction-specific local rules and interpretations in order to meet Pillar Two requirements for global and statutory compliance, including constituent entity analysis, Transitional Safe Harbor assessments, and IIR, UTPR, and QMDTT computations and allocations.
Built on Beacon graph technology, the Pillar Two Engine computes accurate and visually traceable results. It is based on underlying data and uses a centralised rule library that is reviewed by global tax experts.
Our proprietary, cloud-based tech can support your Pillar Two adoption.
Operational readiness
Pillar Two could have widespread impact on your financial operating model requiring early stakeholder engagement and may require additional budget. To address the multitude of challenges, you must ask if your current data model, systems, technology, and processes can support the requirements introduced by this new international tax framework.
We can help you assess your operating model and processes, identify gaps and design solutions for enhanced governance and efficiency that you will need to report and comply with the dynamic Pillar Two environment.
PwC’s technology for Pillar Two
- Total tax management platform
- Pillar Two engine
- Sightline
- Your existing ERP
- Artificial intelligence
Total tax management platform
A technology-driven system for preparing data for Pillar Two quantitative analysis, including data collecting, transformation, processing and integration.
The Total Tax Management Platform automatically collects data from existing technology infrastructure and seamlessly integrates it for analysis, tailored specifically to Hong Kong’s local rules and regulations.
With over 20 tax modules, it streamlines complex compliance management and aids in planning for Pillar Two impacts. The platform allows the export of processed data to the Pillar Two Engine for global calculations.
Pillar Two engine
A centralised, cloud-based calculation engine for quantifying the impact of Pillar Two, including provision, compliance, and modelling.
The Pillar Two Engine is adapted for relevant local rules and interpretations in order to meet Pillar Two requirements for global and statutory compliance, including constituent entity analysis, Transitional Safe Harbor assessments, and IIR, UTPR, and QDMTT computations and allocations.
Built on Beacon graph technology, the Pillar Two Engine computes accurate and visually traceable results. It is based on underlying data and uses a centralised rule library that is reviewed by global tax experts.
Sightline
Built on the latest cloud technology with native AI integration, Sightline is your connected and intuitive tax experience at PwC. Sightline enables a true end-to-end Pillar Two experience. Starting with a dynamic questionnaire powered by our Data Input Catalogue, Sightline integrates seamlessly from your systems to our Pillar Two Engine. No more manual tasks, email overload or complicated tech – take your time back and the stress out of your Pillar Two process with Sightline and our dedicated Pillar Two data and calculations specialists.
Your existing ERP
By leveraging our extensive Pillar Two data expertise, your existing technology infrastructure, and our comprehensive Pillar Two Data Catalogue and Total Tax Management Platform, we can help you enhance and expand the configuration of your Enterprise resource planning (ERP) and Enterprise Performance Management (EPM)/Consolidation systems to address your Pillar Two data challenges. These systems can also be seamlessly integrated with Sightline and our Pillar Two Engine, providing a truly unified experience.
Artificial intelligence
Artificial Intelligence (AI) is integrated into PwC’s Pillar Two process from data collection to interpreting countries’ global minimum tax laws. For example, we leverage AI for language translation and to help determine how local legislation differs from the OECD Model Rules in various countries. For data mapping and transformation, we use AI to validate that the correct source data has been acquired and where that data should map into the calculations.
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