Pillar Two Executive Breakfast Roundtable – 07/04/2026
World Tax Lawyers, in collaboration with STI Taxand, hosted an exclusive Executive Breakfast Roundtable on the 7th of April at The Landmark Nicosia, bringing together senior executives, tax leaders, and advisors to examine the most pressing Pillar Two challenges and priorities for multinational enterprises operating in and through Cyprus.
The session featured Dr. Matt Andrew (PhD in Tax), former OECD Division Head, as keynote speaker, alongside insights from Costas Savva, Christos A. Theophilou, and Demis Ioannou, Partners at World Tax Lawyers and STI Taxand. Discussions focused on how Pillar Two is rapidly evolving from a technical compliance exercise into a core finance, governance, and strategic business issue.
Strong attendance and active engagement underscored the urgency for multinational groups to move beyond theoretical assessments toward practical, decision‑driven implementation frameworks.
Key Discussion Themes:
✔ GLoBE / GIR Readiness Gaps
Most groups remain in assessment mode, with cross‑border data availability, system limitations, and rule interpretation identified as the most significant barriers to meeting initial filing and reporting obligations.
✔ Substance and Tax Optimization
Attention is shifting toward the effective use of Substance‑Based Income Exclusions (QTI) and strategies to minimise top‑up tax leakage, particularly for Cyprus‑based operations.
✔ Safe Harbour Uncertainty
While the Simplified ETR Safe Harbour is widely viewed as a critical mitigation tool, uncertainty persists around eligibility criteria, election mechanics, and sustainability of positions over time.
✔ Transition Rules and Asset Blind Spots
Participants expressed low confidence in the treatment of pre‑transition tax attributes and noted limited analysis on the Pillar Two implications of recent asset transfers and restructurings.
✔ M&A and Joint Venture Complexity
Ongoing deal activity and JV arrangements are giving rise to parallel and highly technical Pillar Two workstreams, requiring dedicated modelling and governance approaches distinct from group‑wide compliance.
Bridging Policy and Practice
The roundtable successfully bridged OECD policy intent with the real‑world implementation challenges facing the Cypriot business community, offering practical insight into how multinational groups can prepare for Pillar Two while safeguarding commercial agility and governance integrity.
This session marks the first in a broader series of executive‑level conversations jointly led by STI Taxand and World Tax Lawyers. Future events will continue to explore Pillar Two developments, strategic responses, and operational best practices for multinational groups in a rapidly evolving global tax environment.
Below you can download the Results from the Questions of the Session as well as the Slides of the presentation!
