A majority of tax executives at large multinational organizations view the upcoming global minimum corporate tax as an impending requirement and are actively preparing for its implementation, a survey by KPMG found. The minimum tax program, known as Pillar Two, established by the Organization for Economic Cooperation and Development (OECD), will require large multinational corporations to pay a 15 percent  minimum tax in jurisdictions where they operate.

According to KPMG' Chief Tax Officer Insights, the firm conducted its survey of chief tax officers and other senior tax leaders of approximately 100 organizations with $1 billion or more in revenue in August.

The survey's key findings included the following:

• Fully 82 percent of the respondents view Pillar Two as a coming requirement that they are actively preparing for, and 15 percent view it as a coming requirement but too early to prepare for. Thus, 97 percent view Pillar Two as a coming requirement that they will need to prepare for. Only 2 percent thought Pillar Two was not likely to be implemented, and only 1 percent were not actively tracking or preparing for it.

• Fifty-seven percent of respondents said they expect Pillar Two to give rise to tax liabilities of $1 to 49 million, 6 percent foresee tax liabilities of $50-$99 million, 9 percent foresee tax liabilities of $100-$500 million and 27 percent foresee no additional tax liabilities.

• Seventy-three percent of respondents said that they had already discussed with their executive management team about the potential incremental compliance/administrative costs associated with Pillar Two. Specifically, 58 percent said they had described their needs but not asked for a larger budget to cover them,  11 percent had asked for and received more budget dollars, and 3 percent had asked and were told, "No."  Only 27 percent said that they hadn't had such discussions or had them only on very high-level terms.

In addition, the survey found that 54 percent of the respondents expect to organize Pillar Two compliance by co-sourcing, while 36 percent intend to manage it in-house, and 9 percent intend to outsource it under an arrangement with an existing provider.

Referring to the 97 percent of respondents who view Pillar Two as a requirement that their companies will need to prepare for, Marcus Heyland, principal at KPMG's Washington national tax office, said, "This is notable, because if you go back a year, that percentage would be much lower," Accounting Today reported.  "At that time, there was some skepticism as to whether Pillar Two would get off the ground. It's interesting that that percentage of companies view Pillar Two as a coming requirement."

Heyland also observed, "The lack of implementation in the U.S. will not slow other countries from implementing their own rules," Accounting Today reported. "But the lack of implementation makes compliance more complicated because the GILTI [Global Intangible Low-Taxed Income] rules have to be addressed in addition to the Pillar Two rules. The degree of complexity is higher for U.S. multinationals than for foreign ones, because they not only have to comply with rules that have already been enacted in the U.S. but also rules that foreign jurisdictions are in the process of implementing."