Cross-border
International tax structuring
The group structure Pillar Two reshapes: holding, financing and IP, with substance and transfer pricing that survive challenge.
International structuringPillar Two advisory
the OECD 15% minimum tax
Pillar Two floors the effective tax rate of large multinational groups (those with consolidated revenue of at least EUR 750 million) at 15% in every jurisdiction. Switzerland collects its own top-up (QDMTT) from 2024, capping the benefit of a low cantonal rate for in-scope entities. We confirm scope, model the top-up and the substance carve-out, and set out the planning that still moves the outcome.
At a glance
The 15% floor, and what it changes.
For large groups only: planning shifts from rate to substance.
- In scope
- Groups ≥ EUR 750m revenue
- Minimum rate
- 15% effective, per jurisdiction
- Switzerland
- QDMTT & IIR from 2024
- Relief
- Substance-based carve-out
- Out of scope
- Smaller groups unaffected
The essentials
What Pillar Two means for a Swiss footprint
Pillar Two, the OECD global minimum tax, ensures multinational groups with at least EUR 750 million of consolidated revenue pay an effective 15 percent in every jurisdiction. Switzerland implemented a domestic top-up tax (QDMTT) and the income inclusion rule from 2024, so a Swiss entity of an in-scope group below 15 percent pays the difference to Switzerland. For large groups, this caps the cantonal-rate advantage and shifts planning towards substance and compliance; smaller groups are entirely unaffected.
Who this is for
- multinational groups at or above EUR 750 million revenue;
- Swiss entities and subsidiaries of large foreign groups;
- groups that chose a low-tax canton now reassessing the benefit;
- in-scope groups facing the new GloBE compliance burden.
Where it fits
Pillar Two reframes the effective-rate planning, raises the value of substance, and interacts with the group’s cross-border structure.
The shift
What it changes for groups
Pillar Two does not raise everyone’s tax — it changes the planning for large groups and leaves smaller ones alone. Knowing which side of the line you are on is the first question.
| In-scope group (≥ EUR 750m) | Out-of-scope | |
|---|---|---|
| Minimum effective rate | 15% per jurisdiction | None imposed |
| Low cantonal rate | Topped up to 15% | Full benefit kept |
| Planning focus | Substance carve-out, GloBE position | Effective-rate optimisation |
| Compliance | GloBE return + Swiss filings | Ordinary returns |
For in-scope groups the lever moves from the headline cantonal rate to the substance-based carve-out, the location of real activity, and collecting the top-up efficiently in Switzerland. For out-of-scope companies, nothing changes. We work out which you are, then model the position that follows.
How it runs
From scope to compliance
Scope first, then model the exposure, then the substance and the filings. The data work is substantial and starts early.
- Stage 1
Scope assessment
Testing the group against the EUR 750 million threshold at consolidated level, and identifying the in-scope Swiss entities.
- Stage 2
Impact modelling
Calculating the GloBE effective rate for the Swiss entities and the top-up, with the substance-based carve-out applied.
- Stage 3
Substance & planning
The substance that improves the carve-out, and the levers that still move the outcome within the rules.
- Stage 4
Compliance
Building the GloBE data, the calculations, and the GloBE Information Return and Swiss filings.
- Ongoing
Monitor
Keeping the position current as the Swiss rules and the group evolve, year on year.
Budget
What it costs
Pillar Two work scales with the group’s complexity: a scope assessment and single-entity model is far lighter than full GloBE compliance across a multi-jurisdiction group. Much of the cost is in the data and the calculations, which are substantial for in-scope groups.
We scope and quote against the group’s structure and the depth of support needed. Pricing is on request.
Discuss your exposure
What you need
What in-scope groups need
Managing a Pillar Two position rests on:
- a clear scope determination at consolidated group level;
- a GloBE effective-rate model for the Swiss entities;
- genuine substance to maximise the substance-based carve-out;
- the GloBE data, calculations and information return;
- the Swiss top-up filings, kept current as the rules develop.
“Too small to be affected” is a group-level question
The error that catches Swiss entities is judging Pillar Two on their own size. The threshold is the consolidated revenue of the whole group, so a modest Swiss subsidiary of a EUR 750 million-plus multinational is in scope and inherits the obligation, while a standalone Swiss company many times its size may be entirely outside it. Assuming a small Swiss entity is below the radar, or that a large one is automatically caught, both lead to the wrong answer. The scope test is the group’s, not the entity’s, and we apply it at that level.
Why Goldblum
Pillar Two: the work behind it
Pillar Two joins international tax, the Swiss top-up rules, substance and heavy compliance. Confirming scope, modelling the exposure and managing the position is the cross-border tax work this firm does for groups.
Scope
The group-level answer
A clear in-or-out determination at consolidated level, so a Swiss entity neither over-worries nor overlooks an inherited obligation.
Modelled
Top-up and carve-out
The GloBE effective rate, the Swiss top-up and the substance-based carve-out quantified for the actual Swiss entities.
Current
Compliance kept up
The GloBE and Swiss filings built and maintained as the Swiss rules continue to develop, year on year.
Related
What Pillar Two touches
The other half
Corporate administration
The substance and presence that make a low effective rate defensible and feed the Pillar Two carve-out.
Corporate administrationStart here
Tax advisory
The effective-rate planning Pillar Two reframes for in-scope groups, and leaves intact for everyone else.
Tax advisory
FAQ
Pillar Two: FAQ
01What is Pillar Two and who does it affect?
Pillar Two is the OECD's global minimum tax: it ensures that large multinational groups pay an effective tax rate of at least 15 percent in every jurisdiction where they operate. It applies to multinational enterprise groups with consolidated annual revenue of at least EUR 750 million. Groups below that threshold are out of scope and unaffected. For those in scope with a Swiss presence, a low Swiss effective rate that falls below 15 percent can trigger a top-up, which is what the modelling and planning address.
02Has Switzerland implemented Pillar Two?
Yes, in stages. Switzerland introduced a Qualified Domestic Minimum Top-up Tax (QDMTT), the Swiss 'top-up tax' or Ergänzungssteuer, from 1 January 2024, and the Income Inclusion Rule (IIR) from the same date, both via a constitutional basis and an ordinance. This means a Swiss entity of an in-scope group whose effective rate is below 15 percent pays the top-up to Switzerland itself, rather than leaving it to be collected abroad. The position continues to develop, so in-scope groups should confirm the current rules for the relevant year.
03What is the Swiss top-up tax (QDMTT)?
The Qualified Domestic Minimum Top-up Tax is Switzerland's own top-up: where a Swiss entity of an in-scope group has an effective tax rate below 15 percent, Switzerland levies the difference itself. The logic is that if a top-up is going to be paid anyway under the global rules, Switzerland would rather collect it than cede it to another country. For groups, it means the benefit of a very low Swiss cantonal rate is capped at 15 percent for in-scope entities, changing the calculus that low-tax cantons were chosen on. We model what that means for the group.
04Does Pillar Two remove the benefit of a low-tax canton?
For in-scope groups, largely yes, at the margin below 15 percent. A canton offering an effective rate of 12 percent no longer delivers 12 percent for an in-scope group's entity there, because the Swiss top-up lifts it to 15 percent. The cantonal rate advantage survives for out-of-scope companies, and substance-based and other reliefs can still matter within the rules. But for a large group, the planning shifts from chasing the lowest rate to managing the GloBE effective rate, substance carve-outs and compliance. We remodel the position under the new logic.
05What is the substance-based carve-out?
Pillar Two includes a substance-based income exclusion that shields a return on tangible assets and payroll from the top-up, recognising real economic activity. The more genuine substance, people and assets, a group has in a jurisdiction, the more income is carved out of the minimum-tax calculation. This makes substance directly valuable under Pillar Two, not just for treaty and residence purposes. For groups, building and evidencing real Swiss substance is part of managing the Pillar Two outcome, which ties the tax planning to the operating footprint.
06What compliance does Pillar Two impose?
In-scope groups face substantial new compliance: calculating the GloBE effective tax rate jurisdiction by jurisdiction, determining any top-up, and filing the GloBE Information Return and the related Swiss filings. The data demands are heavy and draw on the group's consolidated accounts and detailed jurisdictional figures. This is a reporting burden in its own right, separate from the tax itself. We help in-scope groups build the data and the calculations and meet the filing obligations, rather than discovering the compliance gap at the deadline.
07How do I know if my group is in scope?
The primary test is consolidated annual revenue of at least EUR 750 million in at least two of the four preceding years, applied at the level of the ultimate parent's consolidated financial statements. Certain entities are excluded. The threshold is a group-level test, so a small Swiss subsidiary of a large foreign group can be in scope even though the Swiss entity itself is modest. We assess scope at the group level for any company that is part of a large multinational, because the Swiss entity's own size does not answer the question.
08Does Pillar Two affect a small Swiss company?
Only if it belongs to an in-scope multinational group. A standalone Swiss company, or one in a group below the EUR 750 million threshold, is entirely outside Pillar Two and continues to enjoy its cantonal effective rate without a top-up. The rules are aimed at large multinationals. The trap is a small Swiss entity assuming it is too small to be affected when its foreign parent group is in scope. We confirm the group position so a small Swiss company neither over-worries nor overlooks an obligation it inherits from its parent.
09What planning is still possible under Pillar Two?
More than 'none', but different in kind. With the rate floored at 15 percent for in-scope entities, planning shifts to the substance-based carve-out, the location of activity and assets, the interaction with the group's other jurisdictions, and ensuring the Swiss top-up is collected efficiently rather than a foreign one. Out-of-scope parts of a structure still use the full cantonal advantage. The work becomes managing the GloBE position as a whole rather than minimising a single rate. We model the levers that still move the outcome.
10What does Goldblum do on Pillar Two?
We assess whether a group is in scope, model the GloBE effective tax rate and any Swiss top-up for its Swiss entities, quantify the substance-based carve-out and advise on the substance that improves the outcome, and support the GloBE and Swiss compliance and filings. For groups restructuring in response, we work the Pillar Two position alongside the wider tax and substance planning. The aim is a clear, current view of the group's Swiss Pillar Two exposure and the levers that still matter.
Is your group in scope for Pillar Two?
Tell us the group's revenue and Swiss footprint. A partner confirms scope, models the top-up and the substance carve-out, and sets out the planning that still moves the outcome.