What is Pillar Two (the global minimum tax)?
Pillar Two (the global minimum tax) forms part of the OECD’s reform of the international tax system (BEPS 2.0) and is designed to ensure a minimum level of taxation for large corporate groups. The rules introduce an obligation to calculate the effective tax rate (ETR) under a uniform methodology and, in specific cases, to pay top-up tax where the ETR in a given jurisdiction falls below 15%. In Poland, these rules were implemented through the Act of 6 November 2024 on the top-up taxation of constituent entities of international and domestic groups.
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Who do the Pillar Two rules apply to?
The Pillar Two rules apply to large domestic and multinational corporate groups whose consolidated revenue exceeds EUR 750 million (as a rule, in at least two of the last four years). In practice, they also cover Polish subsidiaries within multinational groups, Polish parent entities in large domestic groups, as well as branches and permanent establishments of foreign businesses operating in Poland.
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When is it worth seeking Pillar Two support?
Support in relation to Pillar Two is important already at the stage of assessing whether a given group falls within the scope of the rules and what obligations arise from its structure and business profile. In practice, it is necessary to prepare well in advance – both for ETR calculations and for the new reporting obligations – because the required data set extends significantly beyond standard tax data.
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What are the benefits of preparing for Pillar Two?
Proper preparation for Pillar Two helps reduce the risk of errors in the calculation of the effective tax rate and top-up tax, while also ensuring timely fulfilment of reporting obligations. It also makes it possible to identify available simplifications, such as safe harbours, and to better align finance and reporting processes with the new requirements.
Scope of our support in Poland
As part of its Pillar Two services, Grant Thornton offers, among other things:
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Consultations on the practical application of the GloBE rules and mechanisms
We explain how the Pillar 2 mechanisms (including QDMTT, IIR and UTPR) operate in practice and how they may apply to a specific group structure. We support clients in understanding the local and group‑level implications of the regulations, including potential top‑up tax exposure.
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Interpretation of regulations and legislative developments, including domestic rules and OECD guidance
We assist in interpreting Polish Pillar 2 implementing regulations as well as OECD guidance and explanatory materials. Our support also covers the assessment of planned legislative amendments and ongoing OECD work and their potential impact on tax and reporting obligations.
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Support in implementation projects related to ETR and top up tax calculations
We support organisations in preparing for effective tax rate (ETR) calculations in accordance with the GloBE rules, including the identification of GloBE income and covered taxes. Our services also include data analysis and assessment of the availability of simplifications, such as safe harbour rules.
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Cooperation with group headquarters or foreign teams responsible for Pillar 2 compliance
We act as a local point of contact in Poland, working closely with group headquarters and foreign tax and reporting teams. We help ensure a consistent Pillar 2 approach across the group and support data exchange and the allocation of responsibilities between group entities.
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Workshops and training for finance, accounting and tax teams
We deliver workshops and training sessions explaining the Pillar 2 framework, new reporting obligations and the impact of the regulations on accounting and financial processes. The scope and level of detail are tailored to the roles of participants and the organisation’s stage of Pillar 2 readiness.
How we work: engagement process
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Assessment of the Pillar Two scope
Verification of the EUR 750 million threshold and identification of the entities covered by the rules.
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Review of data and accounting standards
Analysis of available financial data and the principles used in its preparation for GloBE calculation purposes.
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ETR calculation and risk identification
Determination of potential top-up tax exposure and the possibility of applying safe harbours.
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Preparation for reporting
Support with filing obligations, notifications and the GloBE Information Return (GIR).
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Ongoing advisory support and regulatory monitoring
Updating the approach in response to further OECD work and legislative developments.
Verification of the EUR 750 million threshold and identification of the entities covered by the rules.
Why Grant Thornton?
Grant Thornton has a dedicated Pillar Two team combining tax, accounting and reporting expertise. We support both Polish companies and multinational corporate groups in preparing for the new obligations, working directly with group headquarters and international teams. We provide a practical approach to implementing the rules, taking into account both the legislation in force and current OECD guidance, as well as planned legislative changes.
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30+ years
in Poland
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1200+
employees in 7 offices
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2500+
clients