Pillar One
Scope
In-scope companies are the multinational enterprises (MNEs) with global turnover above 20 billion euros
and profitability above 10% (i.e. profit before tax/revenue) with the turnover threshold to be reduced to
10 billion euros, contingent on successful implementation including of tax certainty on Amount A, with the
relevant review beginning 7 years after the agreement comes into force, and the review being completed
in no more than one year.
Extractives and Regulated Financial Services are excluded
Pillar Two
Scope
The GloBE rules will apply to MNEs that meet the 750 million euros threshold as determined under
BEPS Action 13 (country by country reporting). Countries are free to apply the IIR to MNEs headquartered
in their country even if they do not meet the threshold.
Government entities, international organisations, non-profit organisations, pension funds or investment
funds that are Ultimate Parent Entities (UPE) of an MNE Group or any holding vehicles used by such
entities, organisations or funds are not subject to the GloBE rules.