BEPS Pillar Two: Impact on Philippine companies

AS global tax reforms advance, the Organization for Economic Cooperation and Development's Pillar Two initiative is reshaping the tax landscape for multinational enterprises worldwide. In response, in November 2023, the Philippines became a member of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting to uphold tax fairness and protect the country's tax base from aggressive tax avoidance schemes.

Thus, even without adopting Pillar Two, the Philippine companies benefiting from such incentives could still be liable for top-up taxes.Both Philippine-headquartered MNEs and subsidiaries of foreign MNEs will need to support the broader group's compliance. They need to start preparing a host of data for BEPS Pillar Two calculations. Global Anti-Base Erosion compliance requires around 110 core data to calculate the jurisdictional ETR.

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