This paper examines the evolution of the Philippine fiscal incentive regime from the CREATE Act (Republic Act No. 11534) in 2021 to CREATE MORE (Republic Act No. 12066) in 2024, both of which sought to streamline investment processes and harmonize local taxation through mechanisms such as the Registered Business Enterprise Local Tax (RBELT). In the context of the OECD Pillar Two Global Minimum Tax (GMT), the paper discusses the emerging “incentive paradox,” wherein traditional income-based incentives such as the Income Tax Holiday (ITH) and the Special Corporate Income Tax (SCIT) may reduce effective tax rates below the 15% global threshold, thereby triggering top-up taxes in foreign jurisdictions and diminishing the intended benefits of such incentives. The paper further explores how the OECD Pillar Two framework may reshape the future relevance and design of Philippine fiscal incentives, arguing that while GMT is likely to constrain the effectiveness of traditional income-based incentives, fiscal incentives themselves remain relevant as instruments for investment promotion and economic development. However, the changing global tax environment may drive a structural shift in incentive design and policy orientation—from income-based tax reductions toward cost-based, performance-driven, and strategically targeted instruments. The paper underscores the need for a recalibrated Philippine incentive framework that sustains competitiveness, enhances fiscal efficiency, and preserves domestic taxing rights within an increasingly coordinated global tax regime.