Podcast: Pillar Two pregame show - Episode 2

Simplifying the game - Getting to know the safe harbor

Nick Tricarichi

Nick Tricarichi

Partner, Dept. of Professional Practice, KPMG US

+1 571-538-2580

Marissa K. Rensen

Marissa K. Rensen

Managing Director, International Tax, Washington National Tax, KPMG US


Podcast overview

The Pillar Two rules will go into effect at the beginning of 2024 and time is quickly running out for multinationals to determine the impact. The good news is that there is a transitional safe harbor available that can significantly reduce the time and effort required to comply with Pillar Two.

In this episode, KPMG Department of Professional Practice partner Nick Tricarichi is joined by Marissa Rensen, KPMG Washington National Tax managing director, for an engaging conversation about this transitional safe harbor. We tell you how to qualify for the safe harbor and highlight areas that could potentially cause miscalculations. We close the episode by asking Marissa to put on her coaching hat and provide some practical tips on what companies should be doing now to take advantage of the safe harbor.

Want us to answer your Pillar Two questions in our mailbag episode? Submit them here before Nov 16!


  • Multinational companies with consolidated revenues of at least €750M

Relevant dates

  • 2023 year-end reporting – Evaluate whether existing SEC rules require disclosure of the potential effects of Pillar Two
  • January 1, 2024 – Pillar Two rules begin to go into effect
  • Q1 2024 reporting – Account for the effects of Pillar Two in the interim tax provision

Podcast contents

  • 00:15 - Introduction
  • 02:10 - What is the transitional safe harbor?
  • 03:10 - What you need to know about the country-by-country report
  • 07:15 - How to qualify for the safe harbor
  • 10:45 - One strike and the safe harbor is out... what does that mean?
  • 12:10 - Quick recap of how the safe harbor works
  • 12:55 - Coach's Corner: practical implementation advice
  • 15:25 - Closing remarks