CSC Corptax: Leading the Way in Pillar Two Compliance with Corptax GMT

With the EU directive mandating Pillar Two implementation — and with key global economies enacting all or part of Pillar Two — international tax is undergoing significant changes. While many countries’ individual plans are still in flux, tax authorities in South Korea, Japan, Germany, the United Kingdom, and Belgium have already introduced new regulations. 

As this trend continues, businesses will need tax technology to meet the scope and complexity of Pillar Two’s obligations. To help clients respond strategically, Corptax designed a comprehensive solution to meet multiple demands. Corptax GMT gives you everything you need for modeling, planning, provision calculations, and compliance obligations, worldwide.  

Here’s what uniquely equips Corptax to deliver a more powerful solution. 

1. Business Review Team: Centralized Expertise

Our US-based Business Review Team is the cornerstone of our strategic approach to Pillar Two. This centralized task force comprises international subject matter experts, business process experts, and thought leaders with backgrounds in public and private accounting and international tax law. By prioritizing and streamlining processes, this team ensures Corptax reflects regulatory changes efficiently and effectively and gives clients accurate and timely solutions. 

2. Global Reach and Local Expertise

As part of CSC, Corptax leverages the knowledge of 8,000 colleagues in 140 countries. This global-to-local expertise allows us to track emerging legislation, manage filing requirements, and file returns at a local level. Our local specialists ensure we meet the specific needs of each jurisdiction, providing tailored solutions in compliance with local regulations. This global perspective and “boots on the ground” network give clients the ability to better manage the expansive requirements Pillar Two will bring.

3. Single Solution Framework: Centralized, Scalable, and Automated

The Corptax Single Solution framework provides a centralized, scalable, and highly automated approach to international tax management. Our one-of-a-kind framework aligns and standardizes processes and calculations globally, allowing customers to coordinate more easily around the world. With centralized data and standardized processes, clients have full flexibility to model scenarios, configure, and adapt to the changing landscape.

Corptax Response to Recent Developments in Several Countries 

We continually update Corptax GMT according to new regulations. Clients can always trust they’re working with the latest information. 

South Korea

• On March 22, 2024, South Korea amended the Enforcement Regulations to the International Tax Adjustment Act for GloBE adjustments. This includes attachments for various Pillar Two forms, such as the GloBE Information Return (GIR) released in both Korean and English, notification, and Top-up Tax Payment Form. 
• Action Plan: We are reviewing the form instructions to determine whether they will be filed electronically or manually. Given that South Korea’s GIR follows the model closely, our content team is on track to meet all requirements. 

Japan

• On April 12, 2024, Japan published the “Ministerial Ordinance to Partially Amend the Enforcement Regulations of the Corporate Tax Law.” This includes tax return forms in Japanese for reporting Top-up Tax under Japan’s Income Inclusion Rule. 
• Action Plan: We are translating and reviewing these forms to integrate them into our system, ensuring compliance with Japan’s specific requirements. 

Germany

• On May 17, 2024, Germany’s Finance Ministry issued a draft Global Minimum Tax Return for feedback, including draft explanatory guidance.
• Action Plan: We are analyzing the draft form and guidance, expecting it to be filed electronically. Because it’s still in draft form, we are preparing for potential changes and soliciting feedback to refine our approach.

United Kingdom

• On May 20, 2024, the UK issued the Pillar Two Top-up Taxes Registration Notice which explains how to register for Pillar Two Top-up Taxes in the UK. 
• Action Plan: We are reviewing the UK’s requirements, ensuring that our clients can register accurately and on time. The first filing is due in 2025, six months after the year-end.

Belgium

• On May 29, 2024, Belgium published the “Royal Decree of 15 May 2024”, requiring MNE groups and large domestic groups to submit a notification form to register with the Belgian Trade Register by July 15, 2024. It addresses taxpayers planning to prepay their Belgium DTT or Industry Issue Resolution (IIR) by December, although most taxpayers are planning to file later in the year. Belgium has since extended the deadline for the GloBE registration requirements for groups that do not intend to prepay to September 16, 2024.

Action Plan: We are taking a three-pronged approach to respond to the notification requirement:

• Our review indicates that much of the required data is already in Corptax GMT. We are preparing a data map to help our customers organize and access the data required for the notification.
• We are working with our global CSC colleagues to provide support to meet this tight filing requirement. 
• We are determining the feasibility of an XML extract for submission and stay in constant communication with Belgian tax authorities for clarification.

We will provide more information on the Belgium and other notifications soon.

In Closing . . .  

Corptax GMT supports all facets of Pillar Two compliance, empowering clients to confidently navigate the shifting world of international tax. Our centralized international tax expertise, global reach, and Single Solution framework make us a vital partner for businesses responding to new tax regulations. As we closely monitor and adapt to developments in South Korea, Japan, Germany, the UK, Belgium, and beyond, Corptax remains dedicated to delivering comprehensive international tax solutions – giving our clients confidence and peace of mind.