A Life in Tax: The Two Pillars That Shook the World “The Day the Borders Disappeared” It was a Wednesday morning when I got a call from Amaka, CFO of one of West Africa’s fastest-growing fintechs. “Tunji, I just left a strategy meeting. The board’s worried. Apparently, some OECD thing is changing the way we pay tax—even in countries where we don’t have an office. Is this real?” I smiled. The OECD’s Pillar One and Pillar Two were no longer just policy jargon; they were front-row conversations in African boardrooms. Flashback: The Old Way For years, our tax systems relied on physical presence. If a company didn’t have an office, warehouse, or boots on the ground, we couldn’t tax them. Companies like Globax (a fictional Big Tech) sold digital products to millions in Nigeria, Kenya, and Ghana—but paid no corporate tax in those countries. Their profits were booked in Europe or low-tax havens. And then came the OECD’s Inclusive Framework. A reckoning. Pillar One – The Reallocation of Power Pillar One changed the rules of the game. “You mean tax authorities can now tax companies just because people use their app?” Amaka asked, stunned. “Yes,” I explained. “If their global turnover is above €20 billion and their profit margin is over 10%, a quarter of that residual profit will be shared with market countries—like Nigeria—based on user participation.” Even without a single server here. It was revolutionary. And for professionals like me, it meant new skills: Understanding Nexus rules Applying Amount A and Amount B Advising tax authorities on how to compute claims Supporting clients in navigating compliance Pillar Two – No More Tax Havens Then came Pillar Two—OECD's bold answer to profit shifting. I remembered a board meeting in Dubai with a client who had routed nearly all African profits through Mauritius and the BVI. “Tunji, they say we’ll now have to pay a top-up tax if our effective tax rate is less than 15%. Is that true?” “Yes,” I said. “Even if you pay 0% in a haven, your parent company—or another country where you operate—can collect the difference.” The rules are called: Income Inclusion Rule (IIR) Undertaxed Payments Rule (UTPR) And the Subject to Tax Rule (STTR) Every African tax consultant, I realized, needed to study the GloBE rules like the Psalms. Tax Authorities: Between Hope and Hurdles I once spoke at a capacity-building workshop for a West African tax agency. “We love Pillar One,” a senior official told me, “but we don’t have the systems to track global MNE profits or resolve disputes.” This was the silent struggle: Countries finally had rights—but lacked the tools and expertise. Legal frameworks needed updating. Treaties needed renegotiation. Professionals needed upskilling. I saw a gap—and an opportunity: Taxmobile.Online could fill it. For MNEs, the World Got Smaller and More Complicated Big companies began calling weekly. “Tunji, should we restructure our Dubai entity?” “How do we file the GloBE Information Return?” “Can our incentives in Mauritius still hold under Pillar Two?” I realized: This was no longer about compliance—it was global strategy. What I Told My Subscribers In one of my Taxmobile Technical Sessions, a subscriber asked: “Sir, do you think this Two-Pillar system will last?” I replied: “It’s not perfect. Many countries may delay, others may resist. But one thing is clear: the world is tired of injustice. Pillar One and Two are the first step toward fair, digital-era taxation. And Africa must not be left behind.” Final Reflections – A Life in Tax That night, I recorded a voice note to myself: “We’re entering a new era. Where profits can no longer hide in invisible offices. Where value must be taxed where it is consumed. Where tax professionals are no longer just calculators—but architects of fairness.” From Abuja to Amsterdam, from Lagos to London, the tax world is being rewritten. What You Must Do Whether you’re a CFO, tax officer, entrepreneur, or tax professional: Understand Pillar One and Two Learn to advise on GloBE reporting and nexus rules Track which countries have adopted the rules Be ready for dispute resolution and restructuring cases Join tax communities, trainings, and simulations Because in this Life in Tax… The two pillars aren't just global reforms. They are pillars of fairness, pillars of opportunity, and pillars of a new generation of tax professionals—like you and me—shaping tomorrow’s global economy. Olatunji Abdulrazaq CNA, ACTI, ACIArb(UK) Founder/CEO, Taxmobile.Online