M&A Tax Due Diligence Post-Pillar Two: A Buyer's Checklist

Acquisition tax due diligence has been transformed by Pillar Two. A practical checklist for transaction teams.

WTL Research Center

Pillar Two has added a new dimension to acquisition tax due diligence. Buyers must now model the target's GloBE profile alongside the traditional effective tax rate and tax attributes review.

This checklist sets out the minimum tax due diligence scope for acquisitions of groups caught by Pillar Two.

Source Based on reporting by World Tax Lawyers (March 7, 2026) . This piece is an original analysis by the WTL Research Center and does not reproduce the source.

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