Pillar Two compliance roadmap part 4: what data is required?

Once the entity falls within the scope of Pillar Two, various calculations need to be made. To do so, all relevant data should be available. However, many of the data points may not be readily available in the current systems required under Pillar Two. Furthermore, the data is likely to exist across various different source systems, for example, ERP, consolidation system, tax provision & compliance systems but also HR and sales systems, and is owned by different stakeholders in an organization.

Hence, the collection and combining of all relevant data could be very challenging. Good coordination between different teams is required to collect all relevant data for the process. Both the accounting teams, tax teams, and clients must contribute to providing the key data. In its calculations, Pillar Two makes extensive use of commercial financial statements in addition to tax figures, so close collaboration with the accountant is required.

This process is not only about domestic coordination, but also about cross-border coordination. Pillar Two applies to multinational groups, and policies can differ from jurisdiction to jurisdiction. It is essential that teams from different jurisdictions update each other and are aware of important exceptions related to a specific jurisdiction. 

Collecting all relevant data would probably be one of the most challenging parts of the application of Pillar Two for many organizations. As such we advise to start thinking about the data model within your organization sooner rather than later.