Country-by-country reporting crucial to Pillar 2 compliance


The Pillar 2 rules (also referred to as the Global Anti-Base Erosion Rules or the GloBE rules) are designed to ensure large multinational enterprises (MNEs) pay a 15% minimum tax on the income arising in each jurisdiction where they operate. Many countries are embracing Pillar 2, with around 50 different jurisdictions having already legislated the rules or committed to doing so in 2024. Taxpayers in-scope are faced with a significant challenge with regards to preparation for the rules as they begin to be implemented globally.


An article authored by Cory Perry, Grant Thornton Principal, International Tax Services, and Max Cogan, Grant Thornton UK/U.S. Client Specialist, International Tax Services, and published in Bloomberg’s Tax Management International Journal details how Country-by-Country Reporting (CbCR) rules have undergone a paradigm shift in importance because of Pillar 2. Perry and Cogan describe how CbCR, once seen as a procedural formality, is now at the forefront of international taxation discussions because of its impact on the “Transitional CbCR Safe Harbor” provisions included in the rules.


Perry and Cogan walk through the history of CbCR and how it came to rise, while also detailing some of the key financial data required and common pitfalls observed in the market. This includes commentary on its heightened importance as public disclosure of CbCRs also begin to be implemented globally.


Finally, they show how crucial the U.S. CbCR (Form 8975) is for U.S. multinationals now, and perhaps for the first time ever, a report filed with one taxing jurisdiction may directly impact the tax liability in another taxing jurisdiction under the “Transitional CbCR Safe Harbor” provisions.


Click here to read a pdf of the full article, “Global Tax Policy in Transition: The Rising Importance of CbCR.”



Cory Perry

Washington DC, Washington DC

  • Manufacturing, Transportation & Distribution
  • Technology, media & telecommunications
  • Private equity
Service Experience
  • Tax

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