Pillar Two: is the group in scope

Almost everyone remembers the number and forgets the test. The threshold is not «revenue above EUR 750 million last year». It is EUR 750 million reached in at least two of the four fiscal years immediately preceding the one being tested.

That second half changes the answer in both directions. A group that crossed the line once on an unusual year stays outside. A group that crossed it three and four years ago is inside now, even with revenue since fallen. Enter the consolidated revenue of the ultimate parent for the four preceding years and the check counts them.

Preceding year 1, EUR
Preceding year 2, EUR
Preceding year 3, EUR
Preceding year 4, EUR
In scope
Years at or above the threshold2 / 4
Years required2
Threshold€750,000,000
What this does not cover

Scope only, not liability — being in scope says nothing about how much top-up tax, if any, is due. Excluded entities are not checked here: government bodies, international and non-profit organisations, pension funds and certain investment funds sit outside the rules regardless of size. Fiscal years shorter or longer than 12 months require the threshold to be adjusted proportionally, which this check does not do.

Formula source: European Commission — Minimum Corporate Taxation (Directive (EU) 2022/2523, Art. 2)
formula checked 2026-08-18 · Free, no sign-up, nothing sent to our servers.
A calculation under a general rule — not legal or tax advice. It cannot see your treaty position, your substance or the exceptions in your own documents. What the calculators are
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