EU Pillar Two Global Minimum Tax: What SEE Groups Need to Know in 2025

The EU Minimum Tax Directive transposing the OECD Pillar Two rules applies to multinational groups with consolidated revenue above €750 million, introducing a 15% minimum effective tax rate on in-scope profits. EU Member States including Slovenia and Croatia are now applying these rules. For non-EU jurisdictions in the region — Serbia, Montenegro, Bosnia and Herzegovina, and North Macedonia — implementation is at different stages, but the indirect effect through EU parents is immediate.

The relevance for Southeast European groups is asymmetric. Slovenia (19% headline CIT) and Croatia (10% or 18% CIT) are largely above the 15% minimum on a headline basis, but effective rate calculations depend on the specific tax base rules and available incentives. Non-EU SEE jurisdictions with headline rates at 10% (Bosnia, North Macedonia) or 9% on the lower Montenegro tier are more likely to trigger top-up tax calculations at the level of EU parent entities.

In practice, in-scope groups need a Pillar Two readiness assessment covering entity-by-entity effective tax rate modelling, use of available safe harbours, and data infrastructure capable of supporting the GloBE Information Return. Local tax incentives that looked attractive in isolation may, at the group level, generate top-up tax that erases the benefit.

For groups below the €750 million threshold, Pillar Two does not apply directly. However, indirect effects — through supplier, customer, or prospective acquirer relationships — are increasingly real. Below-threshold groups considering growth or transactions should understand where they sit on the effective-tax-rate curve before approaching M&A processes.