Pillar 2 reporting in the Netherlands: what needs to be reported?

Pillar 2 introduces a new layer of reporting complexity for many international businesses. The immediate challenge lies in understanding what needs to be reported, and how this new framework interacts with existing documentation and reporting obligations.

With the first filing deadlines close at hand, our experts discuss data, reporting obligations and opportunities with regard to the Dutch Minimum Taxation Act 2024.

What does Pillar 2 reporting entail?

At the heart of the Pillar Two initiative is the GloBE Information Return (GIR). This reporting instrument is a standardised return, based on OECD standards. The GIR may be shared between tax authorities in aid of checking consistency, liabilities and undertaxation risks. It contains group-wide, detailed information on:

• Group structure;

• Entity-level data;

• Jurisdictional financial results based on financial statements and Pillar 2-adjustments;

• Covered taxes based on financial statements and Pillar 2-adjustments;

• Calculation of jurisdictional effective tax rates; and

• Top-up tax liabilities and allocation.

If the entity that files the GIR is not located in the Netherlands, you are required to notify the Dutch tax authorities which entity will file the GIR, and where. The deadline is the same as the GIR filing deadline: within 15 months of the end of the financial year (with a 3 month extension for the first reporting year, FY 2024). For many organisations, the first deadline is therefore 30 June 2026.

Local top-up tax reporting

In addition to the GIR and relevant notifications, local Pillar 2 top-up tax returns may be required. From a Dutch perspective, a top-up tax return must be filed only if top-up tax is due. In that case, the return must be filed ultimately 2 months after the GIR-deadline; in many cases the first deadline is 31 August 2026.

Please note that the obligations may differ between jurisdictions. Your Baker Tilly advisor would be happy to discuss this with you, and we can make us of our global Baker Tilly International network to see to your local needs.

Key challenge: data, data, data, and more data

To a much greater extent than traditional tax filings, Pillar 2 reporting is highly data-driven and requires specific, consistent, information across jurisdictions. Pillar 2 relies heavily on financial accounting data, rather than purely tax-based metrics. This creates new challenges, with data that must be sourced from multiple systems (ERP, consolidation tools, tax reporting), and adjustments to align local accounting with GloBE rules.

Many organisations have found that their current systems are not configured to capture the required data at the necessary level of detail. Accuracy and consistency across jurisdictions is critical to proper Pillar 2 reporting.

Pillar 2 versus Transfer Pricing: overlap and differences

Some people mistakenly assume Pillar 2 reporting is identical to Transfer Pricing. While both obligations aim to ensure fair taxation, their methodologies, data requirements, and objectives differ significantly.

That said, there are certain areas where transfer pricing outcomes directly affect jurisdictional profits (and therefore Pillar 2 ETR calculations). For example, TP adjustments may have a secondary impact on top-up tax positions. Aligning TP policies with Pillar 2 outcomes can reduce risk and volatility. We advise our clients to bear this in mind, and our advisors actively seek out these opportunities for you.

Read more about the overlap, differences and opportunities here.

Turning complexity into insight

Organisations that treat Pillar 2 purely as a reporting exercise risk missing broader opportunities. Supply chain and operational structures may need reconsideration. Incentive regimes and tax planning may be outdated, sub-optimal, or even counterproductive. And ETR volatility may impact financial reporting and investor communication.

Pillar 2 reporting offers an opportunity to use these and other insights to enhance control and decision-making. By integrating Pillar 2 with existing tax and finance processes, organisations can improve visibility over global tax positions, identify structural inefficiencies and opportunities, align tax planning with business strategy and reduce compliance risks. This requires a coordinated approach across tax, finance, and IT functions.

A proactive approach enables organisations to anticipate these effects and adapt accordingly.

How Baker Tilly can support your organisation

Our multidisciplinary teams help bridge the gap between technical tax requirements and practical implementation. We off end-to-end support for Pillar 2 reporting in the Netherlands, with worldwide support within our global Baker Tilly network, including:

• Pillar 2 impact assessment, including safe harbour eligibility;

• Data readiness assessments and gap analyses;

• Implementation of reporting frameworks and tooling;

• Alignment with transfer pricing policies; and

• Compliance and advisory services.

With our help, you can make Pillar 2 a source of strategic insight, rather than ‘just another compliance obligation’. Would you like to know more about Pillar 2 and our services? Contact our experts: we would be happy to help you.

The legislation and regulations in this area may be subject to change. We recommend that you discuss the potential impact of this with your Baker Tilly advisor.