Assessment of Tax Implications of Managerial Decisions in the Context of the Implementation of the “Pillar Two” Global Tax Regulation

The article explores the implementation of the “Pillar Two” solution under the OECD's global initiative to optimize the taxation of multinational enterprises (MNEs). It analyzes decision-making approaches that governments and MNEs may adopt to assess the implications of the GloBE Rules. Special attention is given to the methodology for calculating the effective tax rate (ETR) and the top-up tax, considering jurisdiction-specific features and tax incentives. The article proposes using modern analytical tools to formalize decision-making processes, evaluate economic and fiscal impacts, and optimize tax planning within the framework of the new global rules. Applying the proposed approach is expected to help minimize competitiveness risks arising from excessive tax burdens and enhance fiscal sustainability amid an evolving global tax landscape.