A global minimum tax of 15%: is it still necessary to relocate taxation in 2026?
- 3 days ago
- 3 min read
Summary
Introduction
Since 2024, the global minimum tax of 15% from the OECD's Pillar 2 has come into force in the European Union and many other countries.
Many entrepreneurs are wondering if this reform makes tax relocation obsolete. The answer depends primarily on your size and profile .
Pillar 2, global minimum tax: what are we talking about?
Pillar 2, led by the OECD , establishes a minimum effective tax rate of 15% on the profits of large groups.
When a subsidiary is taxed below this threshold, an additional tax is levied to reach 15%.
The threshold of 750 million euros in revenue
The scheme only targets groups with at least 750 million euros in consolidated revenue .
The vast majority of entrepreneurs and SMEs are well below this floor .
What Pillar 2 does not change for most entrepreneurs
For a company below the threshold of 750 million, no additional tax is due under Pillar 2.
Residence of individuals against minimum group taxation
Pillar 2 governs the taxation of corporate profits , not the personal taxation of executives who transfer their residence.
An entrepreneur who establishes their personal tax residence abroad remains subject to the residency rules for natural persons.
How low-tax jurisdictions are adapting
Several jurisdictions have introduced a qualified national supplementary tax (QDMTT) to collect the 15% difference themselves.
Dubai, Malta and Cyprus: the top-up reserved for large groups
Relocating a company to Dubai remains attractive, with top-up only relevant for multinational groups exceeding the threshold.
The same applies to a company relocation to Malta or a company relocation to Cyprus , where local schemes remain attractive for medium-sized structures.
Holdings and family wealth: the real points of vigilance
Wealthy families with international holding companies should check whether the consolidated threshold is met at the group level.
Economic substance and flow management
Beyond the rate, the administration examines the real economic substance : offices, managers and decisions actually located on site.
A structure without substance is subject to reclassification , independently of Pillar 2.
Relocating one's residence: a logic that remains unchanged in 2026
For an individual, relocation always relies on the effective transfer of the center of vital interests .
A scheme like tax relocation to Andorra still makes perfect sense for an executive who actually settles his life there.
Pillar 2 summary by profile
Profile | Affected by Pillar 2? | Main issue |
Entrepreneur or SME | No, under €750 million | Residence of people |
International family holding company | According to the consolidated threshold | Economic substance |
Multinational group | Yes, beyond the threshold | QDMTT Supplementary Tax |
Trader or independent | No, natural person | Center of vital interests |
Exit tax, CRS and conventions: the French foundation unchanged
Regardless of Pillar 2, leaving France remains subject to the exit tax on unrealized capital gains.
Anticipate before any transfer
Automatic exchange of information (CRS) and tax treaties require rigorous preparation of the file .
It is best to ensure consistency between residence, income and structure beforehand, before undertaking any action.
Frequently Asked Questions
Does Pillar 2 apply to my SME?
No, in almost all cases. The global minimum tax only applies to groups with consolidated revenue of at least 750 million euros.
Does the 15% minimum tax make relocation pointless?
No. It regulates the taxation of large groups, not the personal taxation of an executive who actually transfers their residence.
Is Dubai losing its appeal with Pillar 2?
Not for medium-sized structures. Local top-up only applies to multinationals exceeding the threshold.
What is a qualified national supplementary tax?
This is a mechanism, called QDMTT , which allows a state to collect the difference of up to 15% itself rather than leaving it to another country.
Is my asset holding company affected?
This depends on the consolidated size of the group . Below the threshold, Pillar 2 does not apply, but the substance remains under review.
Where do I begin to assess my situation?
Through an analysis of your income, mobility, and structures, a personalized study distinguishes what falls under Pillar 2 from what relates to personal residence.
Conclusion
For most entrepreneurs and wealthy families, Pillar 2 does not call into question the interest in relocation : it targets very large groups, not the residence of individuals.
Before making any decisions, it's wise to compare your project to the €750 million threshold, the substance of the transaction, and the exit tax. You can assess your tax relocation options with Coreway Consulting .
