Summary
US-parented groups are exempted from the Income Inclusion Rule and the Undertaxed Profits Rule for fiscal years beginning on or after 1 January 2026, in recognition of US minimum tax rules. The package also adds an ETR-based safe harbour and a safe harbour for substance-based tax incentives.
What it means for you
Groups with consolidated revenue of €750m or more should re-run Pillar Two modelling for 2026.
This summary is general information, not legal advice. The outcome of any case depends on its facts; read the source and take advice before acting.