Title:  Tax Manager (Pillar 2)

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               Tax Manager (Pillar 2)

 
Position purpose

In answer to the perceived tax avoidance/evasion by large multinationals the OECD and G20 initiated Global Anti-Base Erosion rules (typically referred to as ‘Pillar 2’). Pillar 2 aims to ensure a global effective minimum taxation of 15% for all large MNE’s in the countries in which they operate. Most jurisdictions will introduce Pillar 2 from 2024. Pillar 2 is endorsed by approx. 140 countries. All JTI legal entities will be in scope and have to adhere to the new rules.

The new Pillar 2 rules are highly complex. The need for a common way of calculating the income/loss, covered taxes and the effective tax rate (ETR) across so many different jurisdictions which use different principles and bases, drives the inherent complexity of the Pillar 2 jurisdictional minimum tax system. In order to facilitate the group being compliant a specialized team will gather the required financial data, analyse applicability of potential safe harbours, prepare jurisdictional reports, calculate potential top up taxes due, and consolidate all information in one Globe Information Return for JTI.

Pillar 2 constitutes a major change in the international tax environment. Given the material international implications this topic is high on the agenda of all inhouse tax depts of MNE’s, tax consultancy firms, tax authorities, legislators and international organizations like the OECD, UN, G20 and EU. The novelty of the rules, the ongoing political international debates and its applicability to all MNE’s worldwide will not only ensure a dynamic and challenging environment but also that the role will be impactful.

What will you do - responsibilities: 

• Scoping: determine which entities are in scope for which provisions of Pillar 2 and set up a time-line for reporting. Pillar 2 has 3 measures to ensure sufficient 15% taxation of MNE’s: domestic top up tax, income inclusion rules and undertaxed payment rules. Accurate scoping should determine which entities/jurisdiction will be subject to which rule.

• Data collection: if an entity falls within the scope of Pillar 2, various calculations need to be made. Some will be based on CBCR data, other will require standalone IFRS data points. Team will be responsible for inputting appropriate Pillar 2 data in the reporting templates (and updating reporting templates and accounting manual to new developments/changes). As JT data will also be required alignment with JT will be required. Consolidate the individual entity templates into a jurisdictional template.

• Transitional and permanent safe harbours: the new rules have transitional and permanent exemptions to forego full Pillar 2 reporting (‘lighter’ reporting still has to be done even if an exemption applies). Team to ascertain on behalf of entities if criteria for any the exemptions are met.

• ETR calculation: to arrive at the Pillar 2 ETR, ‘covered taxes’ are divided by ‘financial accounting net income or less’. Both metrics require specific adjustments and elections to be made. Determine top up tax per jurisdiction and allocate this tax back to the relevant entities. Obtain sign-off with local management. Analyze and advise management on the outcome.

• Determining which entity pays the tax: in case additional top up tax is due this can be done via a local tax payments under a Qualified Domestic Minimum Top Up tax system which is introduced as part of / in parallel with Pillar 2. Alternatively the top up tax can be due under an income inclusion rule in which case the parent company will have to pay the top up tax. And finally if the first 2 methods do not apply an Undertaxed Profit Rule could apply.

• Filing of the return: Under the Pillar 2 Model Rules, a standardized 'GloBE International Return', which resembles an additional separate tax return has to be filed. The group will have a period of 15 months (or 18 months in the first year when the rules come into effect) to complete and submit the GloBE International Return to the tax authorities. Team will prepare the Globe Information Return for JTI and align further with JT to ensure appropriate filing.

Who we are looking for - requirements:

• University degree
• Tax knowledge and experience
• IFRS or local GAAP Accounting knowledge and experience
• SAP S4 knowledge is a plus
• MS office, advanced user of MS Excel is a must
• Fluent English
• Strong communication skills to communicate complex issues clearly to stakeholders
• Solid analytical and problem-solving skills

What are the next steps in the recruitment process: 

Thank you very much for your interest in recruitment. We will try to come back to you with feedback about the fate of your candidacy immediately after the end of the advertisement for the position.