Third Pillar II Roundtable: Constituent Entities & GloBE income/expense

Date -
Chapter - EMEA

Event Description

Hi All,

If you are interested in the this Roundtable, in order to receive the webinar invitation, please register via this link: Roundtable 3

Registration for already the third Pillar II virtual Roundtable is open: Constituent Entities & GloBE income/expense on March 26. In this Roundtable we will discuss the Pillar II rules qualifying (Constituent) Entities or Entities as Partially Owned Parent Entity, Intermediate Parent Entity, Joint Venture, partly / wholly owned entity, etc. The consequence of such qualification may have an effect on the calculation of the Globe Income, including ‘blending group/scope’ relevant for determining the amount of Adj. Covered Taxes for a jurisdiction. In this Roundtable, Loyens & Loeff will guide us though this complex set of rules and are available to answer all your questions.

Below this message, you can find a summary of the first 2 Roundtables. Closer to date I will follow-up with a message explaining how you can submit questions in relation to Constituent Entities & GloBE income/expense.

We are looking forward to see you on the 26th!

Doris Gonzalez-Hurtado │ Mark Tan │ Mathias Knittel │ Juan Carlos Rubio │ Ralf Thelosen

Roundtable 1 on the Project Approach on January 30

In the first Roundtable, we explored with a panel of TEI members how some companies are getting organized to deal with Pillar Two planning and compliance, from the perspectives of:

  • a US UPE / US-listed MNC
  • a CH UPE / non-listed PE & sovereign wealth fund owned
  • an EU cooperative UPE / non-listed MNC


The discussions touched on how each type of company started their Pillar Two projects, how each went about securing internal and external resources, dealt with questions on the source of data and the link to Country by Country Report data, as well as the technology being used or being explored for modelling and future compliance.


Roundtable 2 on Safe Harbours on February 29

In the second Roundtable, a Deloitte team shared how they approached Pillar Two readiness with their clients, and the 5 step process covering:

  • determining scope,
  • calculating GloBE income,
  • determining covered taxes,
  • calculating ETR and Top-up Tax and
  • applying the IIR and UTPR


This 5 step process also incorporated how the various safe harbours would be taken into account (Transitional CbCR Safe Harbour, QDMTT Safe Harbour, Simplified ETR Safe Harbour, De minimis exclusion and the Transitional UTPR Safe Harbour).


Finally, Deloitte shared working examples of a US UPE with a Dutch IPE holding EU and non-EU CEs, and a US GILTI example dealing with the Blended CFC rules.

Schedule Pillar II Roundtables


Date & Time



Project approach

  • Starting points (heatmap?)
Securing resourcesGeographic / functional vs centralized?Link to CbCRTechnology

January 30, 4.00-5.30pm CET

Doris, Mark, Matthias, Ralf


Safe Harbours

  • How to deal with Qualified CbCR requirement? (e.g. use of taxes from CbCR – question around needing to adjust for Uncertain tax positions)
  • QDMTT (managing time lines)
  • New Guidance

February 27, 4.00-5.30pm CET



Constituent Entities & GloBE income/expense

  • Constituent entities & entity classification – in/out of scope, JVs, POPEs,…
  • GloBE income/expense adjustments (e.g. pension related, stock based compensation,…)
  • How do you identify what needs to be included/excluded?

March 26, 4.00-5.30pm CET

Loyens & Loeff


Covered tax

  • Is local tax qualifying as Covered Tax
  • Deferred Tax positions
  • Tax credit handling
  • Link to Amount B under Pillar 1?
  • Choice of intermediate parent entity to pay any IIR until IIR in parent jurisdiction effective. For US companies, at least until the US enacts something closely resembling Pillar Two, methods of allocation of GILTI (as a qualified CFC tax) among constituent entities
  • For MNCs with operations in Russia, whether the new withholding tax on intercompany services from related parties based in unfriendly states, from 2024, would qualify as a covered tax

April 30, 4.00-5.30pm CET

Baker & McKenzie


Charging mechanism

  • Allocation of Top-up Tax to different entities in a jurisdiction
  • 5 EU MS
  • Plus Switzerland and Austria

May 28, 4.00-5.30pm CET



Dispute resolution preparation

June 25, 4.00-5.30pm CET

DLA Piper