{"id":6033,"date":"2026-04-20T12:58:01","date_gmt":"2026-04-20T02:58:01","guid":{"rendered":"https:\/\/insight.thomsonreuters.com.au\/business\/?post_type=insight_resource&p=6033"},"modified":"2026-04-20T13:04:52","modified_gmt":"2026-04-20T03:04:52","slug":"shifting-dynamics-in-global-taxation-whitepaper","status":"publish","type":"insight_resource","link":"https:\/\/insight.thomsonreuters.com.au\/business\/resources\/resource\/shifting-dynamics-in-global-taxation-whitepaper","title":{"rendered":"Shifting Dynamics in Global Taxation: Whitepaper"},"content":{"rendered":"\n

More than 140 countries have agreed to the Organisation for Economic Co\u2011operation and Development\u2019s (OECD) Pillar Two<\/a>, and over 50 countries have already enacted Global Minimum Tax (GMT) into domestic law. The direction of travel is clear.<\/p>\n\n\n\n

For Australian\u2011headquartered groups and inbound multinationals, this shift lands squarely across tax provision, financial reporting, data governance, and audit readiness. It\u2019s no longer just about future compliance. It\u2019s about what you can explain \u2013 clearly and consistently \u2013 today.<\/p>\n\n\n\n

As one tax leader describes it:<\/p>\n\n\n\n

\u201cA sea of change to global taxation, resulting in an upheaval in international tax rules not seen for almost 100 years.\u201d<\/strong><\/p>\n\n\n\n

This whitepaper brings together perspectives from global tax, finance, and technology leaders to unpack what GMT really means in practice, and how organisations are responding.<\/p>\n\n\n\n

Why Pillar Two is proving so hard to execute<\/h2>\n\n\n\n

At the centre of GMT is a data problem.<\/p>\n\n\n\n

To determine scope, calculate top\u2011up tax, and complete the GloBE Information Return (GIR)<\/a>, multinational groups must collect 200+ data points by entity and jurisdiction. That data spans finance, tax, HR, legal, and operational systems\u2014often owned by different teams, in different formats, across different countries.<\/p>\n\n\n\n

The challenge is amplified by local variation. Countries are implementing Pillar Two at different times, with different combinations of Qualified Domestic Minimum Top\u2011Up Tax (QDMTT), Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR)<\/a>, plus elections, deviations, and transitional safe harbours. Calculations must follow a strict sequence, and often need to be rerun throughout the year.<\/p>\n\n\n\n

As Melvin Song, Head of Tax at CapitaLand Investments, explains:<\/p>\n\n\n\n

\u201cThis absence of a standardised or automated system presents a significant challenge in transitioning from a pre\u2011Pillar Two world to a post\u2011Pillar Two world, where tax provisioning is crucial for calculating the Effective Tax Rate (ETR).\u201d<\/p>\n\n\n\n

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What this means for Australian tax teams<\/p>\n