Two different policy mechanisms
Pillar One addresses the largest, most profitable groups, originally specifying turnover above EUR20 billion and profitability above 10%, with exclusions for extractives and regulated financial services. It allocates a share of residual profit to market jurisdictions. Pillar Two instead sets out coordinated minimum-tax rules, including the IIR and UTPR, and a treaty-based Subject to Tax Rule.
Historical design versus implementation
The document’s thresholds and annexed timetable describe the agreement at that stage. Later model rules, administrative guidance and each jurisdiction’s legislation determine implementation. The downloaded statement carries the 8 October 2021 date while its membership note was updated in June 2023. Read current IRAS Pillar 2 guidance for Singapore obligations rather than treating the original plan as an operative deadline.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
Read the official PDF ↗