Pillar Two

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Services

You want your attention to be on growing and developing your company. You require (financial) advice about issues such as: whether to take care of your...

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Financial administration
An accurate financial administration provides you with the information you need to take the right decisions. The big advantage of a digital financial administration is that it provides insight into your most important financial processes at any time, whether this is the invoices, salary payments or bank changes.
Financial insight
You want to take the right decisions, based on trustworthy and clear management information. You want to have access to all your financial data, 24/7, in order to determine your position and be able to adjust where necessary.
Global compliance partnering
Outsourced compliance services comprises the total financial compliance of your business, in accounting, financial reporting, payroll, legal and various tax reporting obligations. We can make sure you don’t have to worry.

Related insights:

30% Ruling Important Changes to the 30% Ruling per 1 January 2024

On 26 October 2023, the Dutch House of Representative (Tweede Kamer) voted in favour of two amendments which will likely alter the current 30% tax ruling facility.

Louis de Vries

| 3 min read | 01 Jan 2024

Advisory

Everyone – companies, entrepreneurs and individuals – has to deal with taxes. A complex system of payments and levies, tax regimes also offer opportunities for...

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Impact House by Grant Thornton
Building sustainability and social impact. That sounds good. But how do you go about it in the complex world of stakeholders, regulations and frameworks and changing demands from clients and society? How do you deal with important issues such as climate change and biodiversity loss?
Business risk services
Minimize risk, maximize predictability, and execution Good insights help you look further ahead and adapt faster. Whether you require outsourced or co-procured internal audit services and expertise to address a specific technology, cyber or regulatory challenge, we provide a turnkey and reliable solution.
Cyber risk services
What should I be doing first if my data has been kidnapped? Have I taken the right precautions for protecting my data or am I putting too much effort into just one of the risks? And how do I quickly detect intruders on my network? Good questions! We help you to answer these questions.
Deal advisory
What will the net proceeds be after the sale? How do I optimise the selling price of my business or the price of one of my business activities?
Forensic & integrity services
Do you require a fact finding investigation to help assess irregularities? Is it necessary to ascertain facts for litigation purposes?

Related insights:

Sustainability Life Sciences ESG Knowledge Project released its 2025 benchmark questionnaire for investors

The EU Life Sciences ESG Knowledge Project, with participation from 22 Life Science investors, aims to coordinate approaches on ESG within the European Life Science investment community supported by Impact House by Grant Thornton.

| 2 min read | 02 Dec 2024

Audit & assurance

Reliability of information. The way in which reliable information is produced. That is what assurance is all about. It is crucial for information to be...

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Auditing of annual accounts
You are answerable to others, such as shareholders and other stakeholders, with regard to your financial affairs. Financial information must therefore be reliable. What is more, you want to know how far you are progressing towards achieving your goals and what risks may apply.
IFRS services
Financial reporting in accordance with IFRS is a complex matter. Nowadays, an increasing number of international companies are becoming aware of the rules. But how do you apply them in practice?
ISAE & SOC Reporting
Our ISAE & SOC Reporting services provide independent and objective reports on the design, implementation and operational effectiveness of controls at service organizations.
Pre-audit services
Pre-audit services is all about making the company’s entire financial administration ready for checking before the external accountant begins his/her audit of the annual accounts.
SOx law implementation
The SOx legislation dictates that management is structurally accountable for reporting on the internal control relevant to the financial statements.

Related insights:

GTIL GTIL responds to the sustainability standards proposed in Europe

GTIL has submitted its response to EFRAG on the draft European Sustainability Reporting Standards (ESRS).

3 min read | 09 Sep 2022

Tax

Do you have an ambitious international company? And do you want to stay ahead of the competition? Then you need to be able to rely on the best international...

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International corporate tax
The Netherlands’ tax regime is highly dynamic. Rules and the administrative courts raise new challenges in fiscal considerations on a nearly daily basis, both nationally and internationally.
VAT advice
VAT is an exceptionally thorny issue, especially in major national and international activities. Filing cross-border returns, registering or making payments requires specialised knowledge. It is crucial to keep that knowledge up-to-date in order to respond to the dynamics of national and international legislation and regulation.
Customs
Importing/exporting goods to or from the European Union involves navigating complicated customs formalities. Failure to comply with these requirements usually results in delays. In addition, an excessively high rate of taxation or customs valuation for imports can cost you money.
Human Capital Services
Do your employees determine the success and growth of your organisation? And are you in need of specialists which you can ask your Human Resources (HR) related questions? Human Resources (HR) related questions? Our HR specialists will assist you in the areas of personnel and payroll administration, labour law and taxation relating to your personnel. We provide you with high-quality personnel and payroll administration, good HR guidance and the right (international) advice as standard. All this, of course, with a focus on the human dimension.
Innovation & grants
Anyone who runs their own business sets themselves apart from the rest. Anyone who dares stick their neck out distinguishes themselves even more. That can be rather lucrative.
Tax technology
Driven by tax technology, we help you with your (most important) tax risks. Identify and manage your risks and become in control!
Transfer pricing
The increased attention for transfer pricing places greater demands on the internal organisation and on reporting.
Sustainable tax
In this rapidly changing world, it is increasingly important to consider environmental impact (in accordance with ESG), instead of limiting considerations to financial incentives. Multinational companies should review and potentially reconsider their tax strategy due to the constantly evolving social standards
Pillar Two
On 1 January 2024 the European Union will introduce a new tax law named “Pillar Two”. These new regulations will be applicable to groups with a turnover of more than EUR 750 million.
Cryptocurrency and digital assets
In the past decade, the utilization of blockchain and its adoption of a distributed ledger have proven their capacity to revolutionize the financial sector, inspiring numerous initiatives from businesses and entrepreneurs.
Streamlined Global Compliance
Large corporations with a presence in multiple jurisdictions face a number of compliance challenges. Not least of these are the varied and complex reporting and compliance requirements imposed by different countries. To overcome these challenges, Grant Thornton provides a solution to streamline the global compliance process by centralizing the delivery approach.

International business

Expanding into new international markets can be challenging. Where should you expand, how and when? As an international business adviser we can help!

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Expand into new markets
Do you seek for opportunities in the global business arena? Whether you are about to open a new office in a foreign country or considering an international acquisition, you need certainty of making the right choices for your company. Global expansion isn’t always as simple as it sounds. The good thing is that we’re here to help!
Expanding your business in the Netherlands
International expansion is an important step. The Netherlands can be your gateway to Europe for doing business abroad. But why you should choose the Netherlands?
Global contacts
Wherever you choose to do business, you want access to people with the best ideas and critical thinking that will enable you to grow your business at home and abroad.

Legal services

Our corporate lawyers can advise and support you with regard to a wide range of areas at both national and international level.

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Corporate Law
From the general terms and conditions to the legal strategy, these matters need to be watertight. This provides assurance, and therefore peace of mind and room for growth. We will be pro-active and pragmatic in thinking along with you. We always like to look ahead and go the extra mile.
Employment Law
Small company or large multinational: in any company your people are of the utmost importance for your business. Employment brings with it many issues in many areas and often has legal consequences. For big strategic, but also for more everyday questions about employment law, our lawyers are ready to help you out. Also for questions about international employment law. Do you have your own HR department? We’ll gladly assist them. We deliver bespoke services and are there when you need us.
Sustainable legal
Sustainability is more than a buzzword - it is the core of our legal advice towards sustainable success. From drafting sustainable contracts, integrating sustainable HR policies and ESG due diligence within our M&A practice to advising on ESG and other (national and international) legislation: we prefer to be pragmatic and proactive in helping your business.

Industries

Real estate & construction

The building and real estate sector is facing a lot of challenges. Improving sustainability, innovation, but also transformation are important themes. By...

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Family businesses

Family businesses occupy a unique position, in the Netherlands as well as worldwide. They are seen as a (stable) engine of the economy. This is characterized,...

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Transport & logistics

The Netherlands is a real trading country, due to its location, infrastructure and the highly-educated population. The port of Rotterdam, the biggest port in...

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Maritime sector
How can you continue to be a global leader? The Netherlands depends on innovation. It is our high-quality knowledge which leads the maritime sector to be of world class.

Related insights:

Pillar 2 Pillar 2 and the tonnage regulation: watch out for possible additional taxation!

Starting in 2024, a new law for a global minimum profit tax for internationally operating companies will apply in the Netherlands: the 2024 Minimum Tax Act (Pillar 2).

Mirjam Zeldenrust

| 3 min read | 26 Jun 2023

On 1 January 2024 the European Union will introduce a new tax law named “Pillar Two”. These new regulations will be applicable to groups with a turnover of more than EUR 750 million. It includes both a potential tax levy and documentation obligation for the targeted groups if taxation within a jurisdiction falls under the 15% minimum. 138 countries worldwide already agreed to implement Pillar Two in their national legislation. In response to the rapid change of the global economy, multinational enterprises should have the agility and flexibility to adapt to the new economic environment as well as be in compliance with the regulations.

How familiar is your organization with Pillar Two? Does your organization fall within scope of Pillar Two? Do you understand the impact of Pillar Two on your organization? What actions you can take to be prepared? Grant Thornton is here to help. Not only by sharing relevant information and video’s off our compliance roadmap but we also offer you practical services including a risk focused quick-scan, subsequently followed by a review to help take the step from theory to practice.

Pillar Two compliance roadmap: 7 steps approach

Effect on Dutch group entities

The mainrules of Pillar Two

Insight in the legislation and top-up tax through a separate tax system.

What are the exemptions?

Which entities are excluded from Pillar Two

Pillar Two differentiates between Constituent entities and excluded entities.

About the safe harbour rules

The three tests to be met

When is the top-up-tax for a jurisdiction deemed to be zero during the transition period?

What data is required?

Only with complete data you can proceed to step 5

Start thinking about the data model sooner rather than later.

New method to calculate the effective tax rate

Focus on the effective tax rate on a jurisdictional level

Dividing the Globe income by the qualifying taxes.

Who taxes?

Various taxation methods of Pillar Two

Three ways of allocating taxing rights.

Filing return

The GloBE Information return and the top up tax return

Filing obligation of one or even more returns.

Q&A

Our Parent company is in the US, does it also apply for Pillar 2?

Implementation of Pillar Two in the US remains stalled, as proposed changes to the current US global minimum tax — the tax on global intangible low-taxed income (GILTI) — were left out of the recently enacted tax reconciliation bill, the 'Inflation Reduction Act.'

What is the difference between GILTI and Pillar 2 minimum tax? Are they the same thing?

The OECD released Administrative Guidance (‘guidance’) on the Pillar Two Global Anti-Base Erosion Rules (GloBE Rules) on 2 February 2023. The guidance confirms the status of the United States’ minimum tax (known as the Global Intangible Low-Taxed Income, or 'GILTI') as a CFC Tax Regime under the GloBE Rules.

Which countries have a statutory income tax rate before 15%?

Some examples for your reference, Hungary with statutory CIT rate of 9%; Ireland 12.5%; Liechtenstien 12.5%; Qartar 10%; Paraguay 10%, etc. The ETR is more or less the same as the statutory rate, so companies need to be pay extra attention when there is operating entities within these jurisdictions.

Our Parent company is located in a non-EU country with no Pillar 2 compliance yet, will the Dutch BV has the reporting obligation for its subsidiaries located in low-taxed jurisdictions?

Please remember the Netherlands will implement Pillar 2 which will come into effect in 2024 with application of IIR and UTPR, therefore, the Netherlands may levy the additional tax in situations where the Pillar 2 is not implemented in the subsidiaries’ or the parent company’s jurisdictions.

Watch our Pillar 2 webinar

In December 2022, the Member States of the European Union reached agreement on the introduction of a new tax “system”. This new tax system must be implemented in the European Union per 1 January 2024. During this webinar, we will introduce you to the rules of Pillar Two and guide you through the most important topics. You will learn about our 7-step approach and services. And we provide you with answers to relevant questions.

Watch the recording now

Our Services

We are delighted to invite you to our Quick Scan Call. We would like to walk you through the timeline with the latest updates on Pillar Two implementation across the world, while providing you with some takeaways from the Netherlands and EU aspects. Then we will guide you to the Grant Thornton approach, introducing Pillar Two compliance roadmap.

1st focus: Quick scan – Awareness of Pillar Two

We will finish the call with a high-level check on whether you’re your organization is within the scope, and which are the risky entities that may come in a position to pay additional top-up tax. For this call we would only need limited information such as the organizational structure of the group.

Contact one of our specialists

2nd focus: Pillar Two Room

In this round we will focus on the specific status of your group and organization under Pillar Two. The goal of this call is to determine which information needs to be gathered for the companies within the group, based on the potential applicability of exemptions and/or safe harbours, thereby making the first step from theory to practice together with you.

The aim is to provide you with a list of the group companies that may fall within the scope of the exemptions and/or safe harbours, and the information requirements that come with that.

For this, we will need to obtain more detailed financial information beforehand to conduct reviews on exemptions, safe harbours, documentation requirements and potential software/system solutions for data gathering beforehand.

Contact one of our specialists

Moving forward to actions, theory into practice

Such as:

Financial statements/audit file including all companies and PE’s and disregarded/hybrid entities of the group
The most recent CbCr Reporting

This service ties back into our 7 Step Approach and covers the first three steps of these 7 steps to help you get started:

Step 1: determination of scope
Step 2: check of application of exemptions
Step 3: check of application of safe harbours

As such, the Pillar Two Room provides an easy bridge to Step 4: documentation gathering, by including a clear overview of the documentation requirements per group company as part of the deliverable of the Pillar Two room.

Get ready for Pillar Two