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Pillar Two
The global minimum tax of 15% (Dir. art. 3: 15%): whether Pinewood Street Pharma is in scope, what is due in Cyprus and when, and where it meets the transfer pricing.
The global minimum tax: in scope or not, what is due, and the shipping exclusion.
In Scope? No, for 2025
Consolidated revenue of €750,000,000 or more in at least two of the four fiscal years before the tested year (Dir. 2022/2523 art. 2). Swiss parent's consolidated accounts (invented) — to be confirmed with the client.
| Year | Revenue | Counts For 2025 |
|---|---|---|
| 2021 | €545,000,000 | Under |
| 2022 | €590,000,000 | Under |
| 2023 | €640,000,000 | Under |
| 2024 | €710,000,000 | Under |
| 2025 | €780,000,000 | outside the window |
None of the four years before 2025 are over the threshold. If 2025's revenue holds, the group comes into scope for 2027. 2027 would be its transitional year, the first in scope (L.151(I)/2024 s.57): the first top-up tax information return would be due 30 Jun 2029, 18 months after the year end or 30 June 2026, whichever is later.