Key Strategies for Implementing OECD Pillar One

June 17, 2024

Identifying Affected Areas  

To effectively address Pillar One, it is crucial to conduct a comprehensive analysis of your business. This analysis should focus on identifying the areas most affected by the new tax guidelines. Understanding how each section of the business will be impacted allows for more accurate and strategic preparation.  

Tax Simulations and Revenue Mapping  

Using tax simulations is essential to anticipate various scenarios and prepare for potential financial impacts. These simulations should include a detailed mapping of revenues and benefits to market countries. This helps to assess the degree of benefit redistribution needed under the new Pillar One rules.  

Detailed Fiscal Impact Analysis  

Conducting a detailed fiscal impact analysis provides a clear picture of the economic implications. This analysis should include all key areas of the company to ensure a smooth transition and compliance with the new tax regulations.  

Documentation Policies and Internal Training  

Implementing robust documentation policies is critical. These policies must reflect the new profit allocation methodology to ensure compliance. In addition, it is vital to adjust Transfer Pricing agreements between subsidiaries to align with Pillar One guidelines. Internal training plays a crucial role, ensuring that the team is well informed and prepared to migrate to the new documentation model. 

Fiscal Management Automation and Technology  

Automating the creation of Transfer Pricing reports reduces errors and increases accuracy. Investing in tax management software makes it easier to manage and report tax data efficiently. In addition, implementing real-time monitoring systems allows you to quickly adapt to any regulatory changes, ensuring that your company remains in constant compliance. 


Adopting these strategies not only helps to comply with the new Pillar One regulations, but also optimizes tax management and improves documentation accuracy. Preparation and investment in appropriate technology are key to a successful transition and effective compliance.