The OECD's Pillar One and Pillar Two initiatives mark a fundamental shift in global tax rules, requiring multinational groups to reassess their transfer pricing policies, group structures, and effective tax rates across jurisdictions. ForTran helps clients navigate these developments with forward-looking planning and technical precision.

Pillar One: Amount B – Simplified Transfer Pricing for Distribution Functions

Amount B introduces a standardized transfer pricing approach for routine, low-risk marketing and distribution activities. We assist clients in evaluating whether their current arrangements fall within the scope of Amount B, and in benchmarking pricing outcomes against OECD criteria. Our services include policy diagnostics, pilot modeling of affected entities, and adjustment planning to ensure alignment with evolving implementation across jurisdictions.

Pillar Two: Global Minimum Tax and GLoBE Rules

Pillar Two establishes a global minimum tax rate of 15% for large multinational groups, enforced through the Global Anti-Base Erosion (GLoBE) framework. We support clients in assessing effective tax rate exposures, determining top-up tax liabilities, and designing compliant global structures.

Our advisory covers a full range of GLoBE-related issues, including scoping rules, pre-tax profit and loss adjustments, substance-based income exclusions, qualified domestic minimum top-up taxes (QDMTT), and application of the undertaxed payments rule (UTPR). We also guide clients in navigating transitional rules and strategic use of the 15 available elections.

Combining deep knowledge of Chinese tax policy with global implementation insights, ForTran provides clients with tailored solutions to manage compliance risks while maintaining operational flexibility.