Pillar Two: Global minimum tax and notification requirements

The OECD’s Pillar Two framework introduces a global minimum effective corporate tax rate of 15 per cent for large multinational enterprise groups. As the rules are implemented across jurisdictions, affected organisations must not only assess their potential tax exposure but also comply with new reporting and notification obligations.

For many groups, Pillar Two represents a significant shift in international tax compliance. Understanding who is affected, what must be reported and when actions are required is essential to managing risk and avoiding unnecessary administrative burden.

What is Pillar Two?

Pillar Two is part of the OECD’s international tax reform aimed at ensuring that large corporate groups pay a minimum level of tax in every country where they operate. If a group’s effective tax rate in a jurisdiction falls below 15 per cent, a topup tax may apply.

Depending on the group structure and applicable rules, the topup tax can be imposed through:

• the Income Inclusion Rule (IIR),
• the Undertaxed Profits Rule (UTPR), or
• a qualified domestic minimum topup tax in the local jurisdiction.

Which organisations fall within the scope of Pillar Two?

The Pillar Two rules apply to multinational enterprise groups whose consolidated annual revenue exceeds €750 million in at least two of the four financial years preceding the relevant accounting period. Within the EU, the rules also apply to large domestic groups that meet the same revenue threshold in their home country.

For groups within scope, compliance involves both tax calculations and specific reporting obligations, including the GloBE Information Return (GIR) and, in certain cases, a Pillar Two notification.

What is a Pillar Two notification?

A Pillar Two notification is an administrative filing required when a Finnish group entity belongs to a multinational group that submits its GloBE Information Return centrally in another jurisdiction.

In this situation, the Finnish entity must notify the Finnish Tax Administration of:

• which group entity is responsible for submitting the GIR, and
• the jurisdiction from which the GIR is filed.

The notification is submitted via OmaVero. Its purpose is to enable the Finnish Tax Administration to obtain the relevant GloBE information through international automatic exchange of information. Without a valid notification, the Finnish entity may still be required to file the GIR locally.

Pillar Two notification deadlines

Standard deadline: 15 months after the end of the financial year

First filing: 18 months after the end of the financial year

First deadline: 30 June 2026

With the first deadline approaching within the year, now is the time to assess whether your group is in scope and whether a notification obligation applies to your Finnish entities.

Common challenges for multinational groups

In practice, Pillar Two notifications can be challenging due to:

• complex group structures,
• uncertainty over which entity is responsible for filing,
• tight reporting timelines, and
• coordination across multiple countries and stakeholders.

Mistakes or delays may lead to compliance risks, followup questions from tax authorities or unnecessary duplication of reporting.

How Azets supports Pillar Two compliance

Navigating Pillar Two compliance needn't be complicated. Azets offers a dedicated Notification Service to keep your Finnish entities on the right side of the new rules. Our experts manage the entire process on your behalf — from assessing your filing obligation to preparing and submitting the required documentation within statutory deadlines — ensuring compliance, accuracy, and peace of mind in this new regulatory environment. With Azets as your partner, you can focus on your business while we take care of your evolving international tax obligations.