Global Minimum Tax (Pillar Two) & Top-Up Tax Advisory
The 15% global minimum tax is no longer a proposal — it is a computation your group must run, jurisdiction by jurisdiction, every year. For multinational groups with Indian operations, OECD Pillar Two (GloBE) turns familiar questions — where profits sit, which taxes count, how entities blend — into a new compliance layer with real cash consequences. India's own move toward Qualified Domestic Minimum Top-Up Tax (QDMTT) rules means the exposure is not abstract: top-up tax will be collected somewhere. The only question is whether your structure decides where, or someone else's rules do.
A2 Consultants provides end-to-end GloBE compliance and top-up tax impact analysis — modeling your effective tax rate across jurisdictions, quantifying exposure before it crystallises, and restructuring where the numbers justify it.
What we deliver
- Jurisdiction-by-jurisdiction GloBE Effective Tax Rate (ETR) calculation, built on country-by-country data your group already files.
- Identification of covered taxes, GloBE adjustments and available safe harbours — so you compute only where you must.
- Top-up tax computation and jurisdictional blending advisory.
- QDMTT advisory for India and other implementing countries — where domestic top-up rules change who collects first.
- Local and global Pillar Two reporting support (GloBE Information Return and local filings).
- Structuring advice to minimise top-up tax exposure, and strategic restructuring aligned with BEPS 2.0 norms — not bolted on after the fact.
Transfer Pricing Advisory for Digital & E-Commerce Businesses
Digital businesses concentrate exactly what transfer pricing authorities now examine hardest: intangibles, user-generated value, and revenue that crosses borders without goods ever moving. India is among the most assertive jurisdictions on this front — from Significant Economic Presence and the Equalisation Levy to profit attribution for digital permanent establishments. If your intercompany model was documented for a pre-digital business, it is documentation for a company you no longer are.
We structure and document intercompany digital transactions in line with the Indian Income Tax Act and OECD BEPS guidance — designed to withstand audit, not just satisfy a filing deadline.
What we deliver
- TP risk assessment across digital models — SaaS, marketplaces, cloud platforms, gaming, fintech and e-commerce.
- Functional analysis of IP ownership, user-based value creation and data monetisation — where digital TP disputes are actually won or lost.
- Benchmarking and arm's-length pricing for royalties, licensing and intangibles.
- Digital permanent establishment (PE) assessment and profit attribution.
- Master File, Local File and CbC report preparation.
- Equalisation Levy / Digital Services Tax (DST) applicability advisory for India.
- TP planning for new-age models — AI, Web3, digital advertising and platform economies.
- APA and MAP advisory — preventing disputes where possible, resolving them where not.
Who This Is For
- Global SaaS and cloud companies entering or scaling in India.
- International e-commerce marketplaces with Indian sellers or buyers.
- Fintechs, gaming companies and media platforms with cross-border flows.
- MNC groups restructuring for Pillar Two compliance.
- Tax departments preparing for CbCR, QDMTT and digital TP audits.
Why A2 Consultants
Pillar Two and digital TP are not annual compliance events — they are structuring decisions that determine your group's effective tax rate for years. We approach both the way we approach every India engagement: structure first, control early, scale efficiently. One advisory lens across GloBE modeling, transfer pricing, FEMA and repatriation — so the answer that satisfies one regime doesn't create exposure under another.