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Transfer Pricing

August 2026

understanding-of-two-pillar-solution

How Do the Two Pillar Solutions Work?

Introduction

The international tax landscape is undergoing one of the most significant transformations in modern history. Driven by the rapid digitalization of the global economy, Multinational Enterprises (MNEs) have increasingly been able to generate substantial profits in jurisdictions without maintaining a physical presence.

This has challenged traditional international tax and transfer pricing principles, prompting governments and policymakers to seek a coordinated global solution.

The result is the OECD / G20 Inclusive Framework’s Two-Pillar Solution, commonly referred to as BEPS 2.0.

The Two-Pillar Solution aims to address tax avoidance, profit shifting and the taxation challenges arising from digital business models. While Pillar One focuses on reallocating taxing rights among countries, Pillar Two introduces a global minimum tax framework to reduce tax competition and curb base erosion.

Background: Why Was the Two-Pillar Solution Introduced

Traditional transfer pricing rules are based on the arm’s length principle, under which transactions between related entities must be priced as if they occurred between independent parties.

However, digital businesses can derive significant value from consumers and users located in countries where they have little or no physical presence, making the existing framework less effective.

To address these challenges, over 140 jurisdictions participating in the OECD/G20 Inclusive Framework agreed on a Two-Pillar approach designed to:

  • Ensure multinational companies pay tax where economic activities and customers are located.
  • Reduce opportunities for profit shifting to low-tax jurisdictions.
  • Create a more stable and predictable international tax environment.
  • Minimize the proliferation of unilateral digital services taxes.

Pillar One: Reallocation of Taxing Rights

Objective

Pillar One seeks to reallocate a portion of the profits of the largest and most profitable multinational enterprises from jurisdictions where profits are booked to jurisdictions where customers and markets are located.

Under traditional tax rules, profits are generally taxed where a company has a physical presence. Pillar One introduces a new nexus rule that allows market jurisdictions to tax certain profits even without physical presence.

Key Components of Pillar One

1. Amount A

Amount A reallocates a portion of residual profits of large multinational groups to market jurisdictions.

Key features include:

  • Applies primarily to very large and highly profitable MNEs.
  • Focuses on customer-facing and digitalized businesses.
  • Grants taxing rights to market jurisdictions based on revenue generated from customers located there.
  • Reduces reliance on physical presence as a basis for taxation.

2. Amount B

  • Amount B is particularly relevant from a transfer pricing perspective.
  • It provides a simplified and streamlined approach for determining arm’s length compensation for routine marketing and distribution activities performed by local entities. The OECD incorporated Amount B guidance into its Transfer Pricing Guidelines to simplify transfer pricing compliance and reduce disputes.

Benefits of Amount B

  • Simplifies transfer pricing documentation.
  • Reduces audit controversies.
  • Increases certainty for taxpayers and tax administrations.
  • Particularly beneficial for developing and low-capacity jurisdictions.

Pillar Two: Global Minimum Tax

Objective

  • Pillar Two introduces a 15% global minimum effective tax rate for large multinational groups. The goal is to prevent companies from shifting profits to jurisdictions with very low or zero tax rates.

This pillar ensures that multinational profits are subject to a minimum level of taxation regardless of where they are earned

Main Components of Pillar Two

1. Income Inclusion Rule (IIR)

The parent company must pay additional tax if subsidiaries are taxed below the minimum effective rate in foreign jurisdictions.

2. Undertaxed Profits Rule (UTPR)

Acts as a backstop where low-taxed income is not fully captured under the IIR. Other jurisdictions can deny deductions or make adjustments to collect the top-up tax.

3. Qualified Domestic Minimum Top-Up Tax (QDMTT)

Allows countries to collect top-up tax domestically before another jurisdiction applies the IIR or UTPR.

Interaction Between Transfer Pricing and the Two-Pillar Solution[

The Two-Pillar framework does not replace transfer pricing; rather, it operates alongside it.

Transfer Pricing Under Pillar One

Amount B directly affects transfer pricing by introducing standardized returns for routine distribution activities. This can reduce the need for extensive benchmarking studies and lower compliance costs.

Transfer Pricing Under Pillar Two

Although Pillar Two is not a transfer pricing regime, transfer pricing outcomes directly influence:

  • Jurisdictional profit allocation
  • Effective tax rate calculations
  • Top-up tax exposure
  • Financial reporting and tax compliance obligations

Any transfer pricing adjustment may affect the computation of GloBE income and the resulting minimum tax calculations under Pillar Two.

Key Implications for Multinational Enterprises

Multinational companies should prepare for significant operational and compliance changes, including:

Enhanced Data Requirements

Organizations will need detailed financial, tax and transfer pricing data to support Pillar One and Pillar Two calculations.

Transfer Pricing Policy Reviews

Existing transfer pricing models may require reassessment to ensure consistency with both the arm’s length principle and global minimum tax rules.

Increased Compliance Burden

Businesses may need new reporting systems, governance frameworks and technology solutions to manage Pillar-related obligations across multiple jurisdictions.

Potential Reduction in Tax Planning Opportunities

The global minimum tax reduces incentives for shifting profits to low-tax jurisdictions solely for tax benefits

Challenges and Areas of Concern

Despite broad international support, several challenges remain:

  • Complex implementation across jurisdictions
  • Potential overlaps with domestic tax laws
  • Administrative burden for tax authorities and businesses
  • Ongoing uncertainty regarding timelines and local adoption

Organizations must closely monitor legislative developments in countries where they operate and continuously update their tax and transfer pricing strategies

Frequently Asked Questions (FAQ’s)

A: The Two-Pillar Solution (BEPS 2.0) is a global tax framework agreed upon by 140+ countries, designed to address tax challenges from digital business models. Pillar One reallocates taxing rights to market jurisdictions, while Pillar Two introduces a 15% global minimum tax. If your business operates as a large multinational group, these rules directly affect where and how much tax you pay, regardless of where profits are booked.

A: Yes. Under Pillar One’s “Amount A,” market jurisdictions can tax a portion of profits from very large, highly profitable multinational groups, based on where customers and revenue are generated, not physical presence. This mainly applies to customer-facing and digitalized businesses.

A: Amount B provides a standardized, simplified method for pricing routine marketing and distribution activities performed by local entities, reducing the need for extensive benchmarking studies. This means lower compliance costs, fewer disputes with tax authorities and greater certainty in your transfer pricing positions.

A: Yes, potentially. If any of your subsidiaries are taxed below the 15% global minimum effective rate, mechanisms like the Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) may require your parent company (or another jurisdiction) to collect additional “top-up tax”, even if you’re compliant with local tax laws.

A: Businesses should: (1) review and reassess existing transfer pricing policies for consistency with both arm’s length principles and global minimum tax rules, (2) strengthen data governance to support detailed Pillar One and Pillar Two calculations, and (3) build stronger compliance systems, since transfer pricing outcomes now directly impact GloBE income and top-up tax exposure under Pillar Two.

Conclusion

The OECD’s Two-Pillar Solution marks a fundamental shift in international taxation and transfer pricing. Pillar One seeks to redistribute taxing rights to market jurisdictions and simplify certain transfer pricing outcomes through Amount B, while Pillar Two establishes a global minimum tax regime aimed at curbing profit shifting and harmful tax competition.

For multinational enterprises, the message is clear: transfer pricing can no longer be viewed in isolation. Businesses must integrate transfer pricing, global minimum tax considerations, data governance and compliance planning into a comprehensive tax strategy. Those that proactively adapt to the evolving BEPS 2.0 environment will be better positioned to manage risks, ensure compliance and maintain tax certainty in the years ahead.

Wondering how the Two-Pillar Solution impacts your business? Reach out to UJA Global Advisory for expert guidance on transfer pricing and global tax compliance.