Tax advisory

The global minimum tax, known as Pillar Two (the GloBE regime), is the most fundamental change to the international tax architecture in years. Although the rules are aimed at groups with consolidated revenues exceeding EUR 750 million, their substantive impact is felt by all Polish subsidiaries operating within multinational structures. At BTTP, we offer support in analysing these rules, which de facto combine tax law with international accounting standards (IAS/IFRS).

The substantive challenge of Pillar Two is that the Effective Tax Rate (ETR) is calculated not on taxable income, but on accounting profit adjusted for specific GloBE items. Our support includes a precise review of the differences between the local result and group standards, with particular attention to deferred tax and its effect on the 15% threshold.

We help Polish entities prepare data for global reporting (GIR – GloBE Information Return), supporting the collection of information that is not normally required for local CIT. An important aspect of our support is the use of mechanisms such as the Substance-based Income Exclusion — an exclusion based on tangible assets and payroll costs. This helps protect genuine business substance in Poland against additional taxation. At BTTP, we also analyse the Safe Harbour rules, which can significantly simplify reporting during the transitional period.