The 15% minimum tax, widely known as Pillar Two, now applies in dozens of countries to large multinational groups with annual revenue of EUR 750 million or more. The first wave of information returns has been filed, tax authorities are comparing notes, and boards are beginning to ask a simple question: what does this actually mean for us?
That question is where tax advisers come in. The rules are long, technical and still moving. Most finance teams do not have the time to follow every update, and most board members have no interest in the detail. What they want is someone who can explain the impact clearly, tell them what to do next, and help them avoid surprises. In our view, this is one of the largest openings tax advisers have had in a generation, and the firms that step forward now will shape how their clients think about tax for years to come.
The rules are still changing, and that is the opportunity
If Pillar Two had arrived as a finished, stable rulebook, the advisory opportunity would be smaller. It has not. In January 2026, the countries that negotiate these rules agreed a so-called side-by-side package, which introduced new permanent safe harbours, including a simpler test of whether a group's effective tax rate in a country is high enough, and other simplification measures. Several countries have spent 2026 updating their domestic laws to reflect it.
Then, on 11 September 2026, the OECD released a further package. It included an updated version of the standard information return, extra guidance on areas that were still unclear, and a framework for reviewing whether each country's own minimum tax law meets the agreed global standard. The updated return applies to financial years starting on or after 31 December 2025, which means calendar-year groups will be working with it for their 2026 year-end.
One point in that release deserves attention. Simplifications do not automatically mean less work. A group may avoid a full calculation in some countries and still need to gather and report a large amount of data. Even groups whose head office country does not charge a top-up tax may still have extensive reporting to do. This is exactly the kind of nuance that clients miss, and exactly the kind of insight that positions an adviser as indispensable.
Why this matters for the UAE and the wider Gulf
The UAE is a clear example of how Pillar Two has reshaped a tax landscape. For many years, the country was known for having little or no corporate tax. It now has a 9% corporate tax and, from financial years starting on or after 1 January 2025, a Domestic Minimum Top-up Tax that brings in-scope multinational groups up to the 15% minimum within the UAE itself. The idea is straightforward: if a top-up tax is going to be paid somewhere, the UAE would rather collect it at home than see it collected by another country.
The UAE has also moved to adopt the latest OECD guidance into its own regime, which signals that local rules will keep tracking global changes rather than standing still. For groups with operations in free zones, those relying on tax incentives, or those with holding structures set up under the old environment, this creates real questions. Do existing incentives still deliver value? Which entities are in scope? What data does the finance team need to collect, and from where? When is the first local return due, and who is responsible for filing it?
These are not questions a group can answer from a newsletter. They require someone who understands both the global framework and the local rules, and who can translate both into a plan the finance team can follow.
"The advisers who explain the global minimum tax in plain language today will be the advisers boards call first tomorrow." Want your firm to be that voice? FOLD Research helps accounting, tax and advisory firms turn complex rules like Pillar Two into insight articles, briefings and social content that build trust. Write to info@foldresearch.com to start the conversation.
From compliance task to boardroom conversation
It would be easy to treat Pillar Two as another filing obligation, something handled by the tax team once a year. That would be a missed opportunity. The global minimum tax touches almost every major decision a multinational group makes: where to invest, where to place people and assets, whether a government incentive is worth accepting, how to structure an acquisition, and how to present tax figures to investors.
When tax advisers frame Pillar Two this way, the conversation moves out of the back office and into the boardroom. Instead of asking a client to send a trial balance, the adviser is helping the chief financial officer decide whether a planned expansion still makes sense once the minimum tax is factored in. That is a very different relationship, and a far more valuable one.
There is also a reputational side. Investors, lenders and the public are paying closer attention to how much tax large groups pay and where. Boards want to be confident that the numbers they report are right and that they can explain them. An adviser who helps them do that becomes a trusted partner rather than a service provider.
Where tax advisers can add the most value
The first area is impact assessment. Many groups still do not have a clear, country-by-country picture of where they might owe top-up tax and why. A focused review that tests the safe harbours, identifies the countries that need full calculations, and puts a number on the likely exposure gives leadership something concrete to act on.
The second area is data and systems. The single biggest practical challenge with Pillar Two is data. The calculations draw on accounting figures, deferred tax balances, payroll costs and asset values, often from many entities in many countries. Advisers who can help design a repeatable process, rather than a one-off spreadsheet exercise, will save clients time and risk every year.
The third area is incentive and structure review. Tax holidays and reduced rates that once made a location attractive may now simply shift where the top-up tax is collected. Advisers can help clients understand which incentives still create real value and which ones need to be rethought.
The fourth area is ongoing monitoring. With a formal review process now in place for countries' minimum tax laws, and further guidance likely, clients need someone watching the horizon. A regular update service, delivered in plain language, keeps advisers close to their clients between filing seasons.
The fifth area is education. Boards, audit committees and finance teams all need to understand Pillar Two at different levels of detail. Short briefings, clear written explainers and practical workshops are an easy way for advisers to show expertise and build demand for deeper work.
Leading the conversation, not following it
The advisers who will benefit most from the global minimum tax are not necessarily the largest. They are the ones who speak first and speak clearly. A well-written article explaining what the September 2026 package means for local groups, a short note on how the UAE minimum tax interacts with free zone benefits, or a straightforward guide to preparing for the first local return can do more for a firm's reputation than months of cold outreach.
Clients are looking for guidance now, while the rules are still settling. Firms that publish consistently, explain simply and connect technical updates to business decisions will be the ones clients remember when it is time to appoint an adviser. The opening is real, but it will not stay open forever. As the rules mature and the market fills with commentary, the advantage will shift to those who established their voice early.
The bottom line
The global minimum tax is no longer a future event. It is live, it is evolving, and it is raising questions that most businesses cannot answer on their own. For tax advisers, that combination of complexity, change and board-level relevance is a rare opportunity. The firms that treat Pillar Two as a strategic conversation rather than a compliance chore, and that share their thinking openly and clearly, will lead the market. The rest will be left responding to questions their clients have already taken elsewhere.
Frequently asked questions
What is the global minimum tax?
The global minimum tax, also called Pillar Two, is an internationally agreed rule that aims to make sure large multinational groups pay at least 15% tax on their profits in every country where they operate. If a group pays less than 15% in a country, a top-up tax can be charged to make up the difference.
Which businesses are affected by Pillar Two?
The rules generally apply to multinational groups with consolidated annual revenue of EUR 750 million or more in at least two of the previous four years. Smaller businesses are usually outside the scope, although they may still be affected if they are part of a larger group.
Does the UAE apply the global minimum tax?
Yes. The UAE introduced a Domestic Minimum Top-up Tax for financial years starting on or after 1 January 2025. It applies to in-scope multinational groups and tops up their UAE tax to the 15% minimum, so that any extra tax is collected in the UAE rather than abroad.
What changed in the OECD's 2026 updates?
In January 2026, countries agreed a side-by-side package that added new permanent safe harbours and simplifications. In September 2026, the OECD released an updated information return reflecting those changes, along with additional guidance and a framework for reviewing whether countries' own minimum tax laws meet the global standard.
Do safe harbours mean less compliance work?
Not always. Safe harbours can remove the need for full calculations in some countries, but groups may still need to collect and report a significant amount of information. Every group should check what the updated reporting requirements mean for its own data and processes.
Why is Pillar Two an opportunity for tax advisers?
Because the rules are complex, still changing and relevant to major business decisions. Clients need help assessing their exposure, building reliable data processes, reviewing incentives and keeping up with new guidance. Advisers who explain these issues clearly can move from compliance support into strategic, board-level advice.
How should tax advisers start building authority on Pillar Two?
Start by publishing clear, practical insights on how the rules affect your clients' markets, run short briefings for finance teams and boards, and offer a focused impact review as an entry point. Consistent, plain-language content builds trust faster than technical commentary alone.
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This article is for general information only and does not constitute tax advice. Groups should seek specific professional advice on their own circumstances.