Business at OECD (BIAC) strongly supports the continued work on Pillar Two and welcomes the OECD Forum on Tax Administration Amsterdam Dialogue as an essential channel for cooperation among tax administrations and the business community. As countries move from rulemaking to real-time implementation, coordinated and consistent approaches are critical to ensuring that the global minimum tax achieves its objectives without disproportionate administrative burden in tax compliance and tax administration.
The Amsterdam Dialogue was initiated by the OECD Forum on Tax Administration in late 2024 following a joint seminar held by the OECD and the Netherlands Tax Administration in Amsterdam. Business stakeholders, including the Business at OECD Tax Committee members, participated in the seminar and have been part of the ongoing dialogue. Through Business at OECD’s Tax Committee and the Pillar Two Business Advisory Group (BAG), Business at OECD is working closely with the OECD to help ensure that Pillar Two rules are administrable for both taxpayers and tax authorities. This engagement aims to reduce unnecessary complexity, promote predictability, and support a smooth compliance experience as jurisdictions roll out their domestic frameworks.
Business at OECD believes that the Amsterdam Dialogue is valuable in enabling transparent discussions on implementation challenges that businesses are experiencing in real time—from registration hurdles, inconsistent deadlines, and portal readiness to the need for clear filing formats, central filing confirmations, and proportionate penalty frameworks. Business at OECD appreciates the OECD Forum on Tax Administration’s efforts to surface these issues and provide practical solutions. At the same time, Business at OECD encourages continued refinement to further enhance certainty, ensure infrastructure readiness before deadlines, and reduce duplicative or unnecessary compliance burdens.
A key priority for business is avoiding fragmentation. Divergent domestic approaches increase cost, complexity, and operational risk for multinational enterprises and strain tax administration resources. Business therefore hopes that the Amsterdam Dialogue will be leveraged by countries as an important channel for communication and coordination on common issues relating to implementation. Alignment on filing requirements, terminology, deadlines, and the use of group financial-year references—alongside consistent registration, notification, and data retention practices—would greatly enhance predictability and reduce administrative burden for all stakeholders.
Continued structured engagement will help ensure that technical clarifications are well understood, compliance expectations are realistic, and administrative frameworks evolve in a coordinated manner.
The business community stands ready to continue contributing constructively to this process. Stakeholders may engage through their national business federations or directly via the Business at OECD Business Advisory Group, which consolidates technical insights from companies across sectors and jurisdictions.
Business at OECD remains committed to collaborating with the OECD and governments to help ensure that Pillar Two achieves its intended objectives while keeping compliance manageable, predictable, and administratively efficient.
For further information, please contact:
Business at OECD
Max Jablonowski, Communications Manager (jablonowski@biac.org)
About Business at OECD
Established in 1962, Business at OECD (BIAC) stands for policies that enable businesses of all sizes to contribute to growth, economic development, and societal prosperity. Through Business at OECD, national businesses and employers’ federations representing over 10 million companies provide and receive expertise via our participation with the OECD and governments promoting competitive economies and better business.
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