Pillar 2: What SMEs Need to Understand Before 2026

Pillar 2: What SMEs Need to Understand Before 2026.

The introduction of OECD Pillar 2 represents a major shift in international taxation.

While primarily targeting large multinational groups, its effects extend well beyond them, indirectly impacting many SMEs.

Here is a clear and practical overview.

1. What is Pillar 2?

Pillar 2 is part of the OECD BEPS 2.0 project.
It introduces a 15% global minimum effective tax rate, calculated under the GloBE rules.

Its purpose is to limit aggressive tax planning and ensure a minimum level of taxation in each jurisdiction.

2. Who is directly affected?

Pillar 2 applies to:

• multinational groups

• with consolidated revenue exceeding EUR 750 million

• in at least two of the previous four financial years

Switzerland has implemented these rules into domestic law.

3. Why SMEs should also pay attention

Even if an SME does not meet the threshold, it may still be impacted if:

• it belongs to a qualifying international group

• it is a Swiss subsidiary of a foreign group

• it must provide financial data for GloBE calculations

• it is involved in intragroup transactions

👉 Main risk: underestimating the operational and data requirements.

4. Key timeline

• FY 2024: first periods covered

• Until 30 June 2026: transitional deadlines for certain filings

• From 2026 onwards: full application

👉 Data preparation must start well before filing deadlines.

5. Key practical challenges

Pillar 2 is not just a tax issue:

• specific accounting adjustments

• differences between statutory accounts and GloBE calculations

• coordination across entities

• enhanced documentation

• interaction with accounting, reporting and audit

Poor anticipation may lead to compliance risks and increased costs.