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The Pillar Two rules are a new set of tax rules developed by the OECD which are intended to ensure that groups with consolidated revenues of over €750m pay a minimum tax rate of 15% on their income, calculated under specific Pillar Two principles.

Trusts are entities for Pillar Two purposes, and can be required to file tax returns and make tax payments in relation to both their own income and income arising in companies in which they have a shareholding. The fact that a trust has investments in two separate corporate groups can also bring the corporate groups within the scope of the rules when they would not otherwise be, because it may result in multiple companies or groups being combined in considering the €750m threshold.Trusts can have filing and tax payment obligations under the Pillar Two rules, and whether groups are in scope is determined on the basis of a deemed accounting consolidation, which can be difficult to apply to investments owned by trusts.