Compliance Briefing — December 15, 2022

Executive briefing: On December 15, 2022, the EU Council unanimously adopted Directive (EU) 2022/2523 implementing the OECD/G20 Pillar Two 15% global minimum tax. In-scope groups (consolidated revenue ≥ €750 million) must prepare for 2024 income inclusion and undertaxed payment rules, harmonised data collection, and detailed top-up tax computations across EU jurisdictions.

Immediate compliance priorities

Scoping analysis. Identify entities and joint ventures falling under the directive, evaluate safe harbour eligibility, and map transition rules for newly in-scope groups.
Data readiness. Catalogue financial statement data, deferred tax attributes, and covered taxes needed to compute jurisdictional effective tax rates per Articles 27–34.
Reporting roadmap. Establish processes for GloBE information returns and local top-up tax filings, aligning due dates with domestic transposition calendars.

Control alignment

Technology enablement. Upgrade consolidation and tax provision systems to capture Pillar Two adjustments, safe harbour elections, and audit trails.
Governance. Refresh tax risk management frameworks so audit committees oversee minimum tax readiness, policy updates, and controls testing.
Intercompany coordination. Harmonise data definitions and chart-of-account mappings across subsidiaries to prevent reconciliation breaks during GloBE reporting.

Enablement moves

Develop prototype top-up tax calculations using 2021–2022 data to validate process design, safe harbour impacts, and resource needs.
Align Pillar Two analytics with CSRD and transfer pricing disclosures to maintain a coherent narrative for tax transparency reporting.
Engage with national tax authorities early to understand administrative guidance, simplified filing options, and local penalty regimes.

Sources

Zeph Tech supports Pillar Two programmes with jurisdictional data lineage mapping, tax technology configuration, and audit committee briefing materials.