SystemTax Compliance & Tax Technology

Pillar Two Compliance

Pillar Two compliance software that tests every country, traces every field and has the GloBE return ready months before the deadline

Every country tested, every field traced, the return ready months before the deadline.

See one case, screen by screen ↓
demo27of 30countries in a transitional safe harbour after one run of the agents
demo€1.84MIrish top-up tax once the deferred tax adjustment is counted, not €8.28M
target100%of return fields traced to a source document and cell
target168daysbefore the filing deadline, the return complete
In short

What is Pillar Two Compliance?

Software that proves a multinational group pays at least 15% in every country under the OECD global minimum tax: it collects the entity data, runs the safe-harbour tests, calculates top-up tax and prepares the GloBE Information Return and the local returns. Pillar Two Compliance does this with seven agents that pin all 268 return fields to their source, test every country, propose GloBE adjustments with the OECD rule for each, re-perform the results and tie the return to the CbC report. The Head of Tax signs every election before anything is filed.

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Updated

The problem

Why the GloBE return eats the tax team's year

From FY2024 a group with consolidated revenue of €750M or more must show an effective tax rate of at least 15% in every country it operates in, in a 268-field GloBE Information Return. Each entity feeds it more than 200 data points from the ledger, the consolidation, the country-by-country report, the tax provision, payroll and the fixed-asset register. Today the Pillar Two manager sends templates to 30 local controllers, and the values come back by email in spreadsheets, weeks late, with no trace of the cell they came from.

Then the safe-harbour tests are run by hand from the CbC report, and the countries that fail need the full calculation: adjustments to accounting profit and covered taxes, deferred tax recast at 15%, the substance carve-out at the transition rates. A missed deferred-tax line overstates the top-up tax. A safe harbour lost through bad CbC data is lost for good — once out, always out. And the elections are approved in email, while the auditor asks for the trail.

typical200+data pointsper entity, drawn from finance, tax, HR, legal and operations
typical15monthsafter year end, the return is due — 18 for the first year
typical~40countriesrequired Pillar Two filings for 2024
Where a year's return goes, in working daysestimated
By hand98 days
With the solution18 days
  • Scoping entities, ownership and exclusions10 → 1 d
  • Collecting data from local controllers40 → 8 d
  • Running the safe-harbour tests for every country10 → 1 d
  • Full GloBE calculation for the countries that fail15 → 3 d
  • Assembling, tying out and validating the return15 → 3 d
  • Elections, sign-off and the auditor's questions8 → 2 d

Estimated split for one year's GloBE return of a group with about 200 entities in 30 countries, by hand and with the solution.

How it works

How the return is built

Seven specialist agents test every country, pin every field and calculate the top-up tax; the Head of Tax signs every election.

What comes in
Entity data in214 entities · ledger, CbC report, provision, payroll, assets
Agents at work
Entity and ownership agent214 entities
Then
Data agent268 fields pinned
Then
Safe-harbour agent
Adjustment agent
Top-up calculator
Then
Checkerre-performs
Filing agentreturn + local returns
A person decides
Head of Taxsigns every election
What comes out
GloBE return
Local returns
Top-up known
One case, step by step

One group's FY2025 return, from open fields to ready to file

Kestrel & Vane Group has 214 constituent entities in 30 countries and reports in euros. Its FY2024 return was filed centrally in the Netherlands on 26 June 2026; the FY2025 return is due on 31 March 2027. It is Wednesday 14 October. Here is what happens next, screen by screen, in the working solution.

  1. 01Wednesday morning

    Thirty countries on one ladder, and one click

    Sofia Marchetti · Head of Tax

    Sofia's home screen is the ETR ladder: every country a rung sorted by rate, with a bold line at 15%. Five sit below it, from the UAE at 9.6% to Ireland at 13.2%, and 236 of the 268 return fields are filled and pinned. Under Needs you: a new Irish provision workpaper arrived at 07:48. She clicks Run the agents, and the first step is the plan.

    “Plan · 7 agents, 30 countries, 32 open fields — new since the last run: provision workpaper IE-25 and 2 controller replies.”

  2. 02Seconds later

    27 of 30 countries in a safe harbour, €3.12M of top-up

    The agents

    The Safe-harbour agent runs the three transitional tests for every country: 25 pass the simplified ETR at 16%, Hungary passes routine profits (€18.4M against a €21.7M carve-out) and Bulgaria is de minimis. Ireland, Singapore and the UAE fail all three and get the full calculation. The badges change on every rung, the top-up appears on the right, and Needs you now reads: 7 elections need your signature.

    “Agents finished · 261 of 268 fields · 7 elections wait for you.”

  3. 03Missing values

    Eleven gaps filled, two from the controllers' own replies

    Data agent

    The Data agent fills the 11 missing values and pins each to its document and cell: Ireland's deferred tax from workpaper IE-25 rows 14–31, Singapore payroll, UAE and Hungary assets. The Poland BEPS TIN for KV Polska Logistyka and the Brazil ownership of Andes Vane Embalagens are read back from the local controllers' replies, at 100% confidence. Nobody re-keys a spreadsheet.

    The Data agent never enters a value without a source; below 85% confidence it asks a person.

  4. 04Ireland

    From accounting profit to top-up tax, every line pinned

    Top-up calculator and Checker

    Ireland's six entities fail all three tests at a simplified ETR of 13.2%. The bridge runs from €482.0M profit before tax to €486.1M of GloBE income, and covered taxes to €70.97M: a GloBE ETR of 14.6%. After the €26.1M substance carve-out, excess profit is €460.0M and the top-up is €1.84M, paid in Ireland under its domestic top-up tax. Beside it, the Checker's separate run agrees on every figure.

    Checker: “Disagreed on Tue 13 Oct with the asymmetric FX item at KV Treasury DAC (71% confidence) and escalated it … Cannot clear its own flags.”

  5. 05The line that matters

    The deferred tax adjustment, with its rule and its source

    Adjustment agent

    The highlighted line is today's: a deferred tax adjustment of €6.80M, found in the provision workpaper Ciarán Byrne, Ireland's finance controller, sent at 07:48. One click opens the source: rows 14–31 of IE-25, the recast at 15%, the valuation-allowance movement excluded and the recapture test. Without it, Ireland's top-up would be €8.28M.

    “Deferred tax charge €7.1M at 12.5%; recast at 15% and less €0.9M valuation-allowance movement excluded under Art. 4.4.1(c) → €6.80M. Recapture test (Art. 4.4.4): no balance older than five years.”

  6. 06Review

    Every adjustment with its article, decided by a person

    Daniel Okafor · Pillar Two Manager

    Each adjustment shows its amount, its effect on the rate, the article and the OECD guidance behind it, its source and the Checker's verdict. Daniel has accepted eight. Two were escalated by the Checker: the asymmetric FX item at KV Treasury DAC, which he accepted on Group Treasury's memo, and a Singapore development incentive, which he rejected. Today's four proposals take €6.95M off the top-up across three countries.

    Daniel's reason, on the Singapore incentive: “Checker is right: the award reduces the rate and is not refundable.”

  7. 07The cost

    €3.12M, all paid where it arises

    Top-up calculator

    The top-up schedule lists the three countries that fail every test: Ireland €1.84M, Singapore €0.80M at a GloBE ETR of 12.9%, the UAE €0.48M at 9.9%, each collected by its domestic top-up tax and due 31 March 2027. Nothing is due at the parent in the Netherlands. Before today's adjustments, the total stood at €10.07M.

  8. 08Next year

    A warning while the year is still open

    Safe-harbour agent

    Switch the safe-harbour tests to FY2026 and the simplified ETR test rises to 17%. Switzerland at 16.4% and Romania at 16.9% fall out, and neither passes routine profits, so both would need the full calculation. The agent re-tests every month on the latest close, so the tax team can act now.

    “Once a country leaves the transitional safe harbour it cannot return.”

  9. 09Tie-out

    The return against the CbC report: 29 of 30 tie

    Checker

    The Filing agent validates the draft against the OECD schema and the team's own checks, and the Checker ties every country back to the CbC report. Poland is €2.3M apart on revenue: a dividend from KV Polska Logistyka to KV Polska Holdings counted as revenue in the CbC report. Poland's simplified ETR is 18.8% on either figure, so the test result does not change. Daniel resolves it with a reason code.

    Reason code: “Agree with the rule and the source.”

  10. 10Signed · 10:48

    Seven elections signed, the return ready to file

    Sofia Marchetti · Head of Tax

    Each election shows its lock-in, its effect and its evidence: the transitional safe harbour for 25 countries, for Hungary and for Bulgaria; the domestic top-up safe harbour for Ireland, Singapore and the UAE; and Ireland's five-year stock-based compensation election. Sofia signs all seven with the reason code “Tested and evidenced”, and accepts today's four adjustments as she signs. All 268 fields are done, 168 days before the deadline.

    “All 7 elections signed · 268 of 268 fields · the return is ready to file.”

Who it’s for

Built for everyone who carries the return.

The same FY2025 GloBE return, seen by four of the people who carry it — what the year looked like, and what it looks like now.

SM
Sofia MarchettiHead of Tax, Kestrel & Vane Group · signs every election
Head of Tax
Before
“I sign it, so I want to see where every number came from.” Elections reached her in email, with the evidence somewhere else.
Now
Sees every country on one ladder against the 15% line, opens any number to its source, and signs each election with its lock-in and evidence in front of her.
DO
Daniel OkaforPillar Two Manager · accepts adjustments, manages 30 data owners
Pillar Two Manager
Before
“Half my quarter goes on chasing spreadsheets.” He ran the calculation and reviewed every adjustment by hand.
Now
Reviews adjustments that arrive with their article, source and a second agent's verdict, and decides the ones the Checker escalates.
MT
Mei TanakaTax Data Analyst · maps the data, prepares the return
Tax Data Analyst
Before
“The GIR fields are not in any system we have.” She mapped ledger and CbC data to the template and chased the gaps.
Now
Watches 268 fields fill with a source pin and a confidence on each, and sees controllers' replies land in the right field.
HV
Hanne VosAldermoor & Pell LLP · statutory auditor, read-only
Statutory auditor
Before
“Show me the source and who approved it.” She asked for the trail behind the top-up tax provision and the elections.
Now
Reads every number, source and signature in a read-only view, and takes the evidence pack for her working papers.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven specialist agents test every country, pin every field and calculate the top-up tax; the Head of Tax signs every election.

Entity and ownership agent

Builds the constituent-entity list and the ownership chains from the legal-entity register and the consolidation, and flags joint ventures, minority-owned and excluded entities.

  • Never changes a source system
  • Never decides an exclusion
Data agent

Maps ledger, consolidation, CbC, provision, payroll and asset data to the 268 return fields and pins every value to its document and cell; writes to data owners for gaps, chases when an answer is late and reads their replies back.

  • No value without a source
  • Asks a person below 85% confidence
Safe-harbour agent

Runs de minimis, simplified ETR and routine profits for every country with the rate for the fiscal year, the domestic top-up safe harbour, and next year's rate cliff.

  • Recommends elections, never makes them
  • Checks the once-out, always-out rule every year
Adjustment agent

Proposes GloBE adjustments to income and covered taxes, each with its amount, article, OECD guidance paragraph, source, confidence and effect on the rate.

  • Every proposal cites the rule
  • Never accepts its own proposal
Top-up calculator

Calculates the GloBE ETR, the substance carve-out at the transition rates, excess profit, top-up tax and which country collects it.

  • Calculates only on accepted or proposed inputs, and labels which
Checker

Re-performs every ETR and top-up independently, in a separate run from the same sources, ties the return to the CbC report and the provision, and challenges the other agents.

  • Cannot clear its own flag
  • Escalates disagreements to a person, never averages them
Filing agent

Assembles the GloBE Information Return, validates it against the OECD schema, prepares the local returns and notifications and keeps the filing calendar.

  • Never files
  • Marks the return ready only when every election is signed
Head of Tax

Signs every election. The agents propose; a named person decides.

Ask in plain words

Ask about the return, in plain words

Ask about any country's rate, a safe harbour, an election or a deadline — or ask for a draft. Every answer points to its source, and nothing is sent until you approve it.

Why is Ireland below 15%?

Ireland fails the simplified test at 13.2% (income tax €63.6M on profit €482.0M), so it needs the full calculation. On GloBE income of €486.1M its covered taxes were €64.17M until this morning's provision workpaper added a €6.80M deferred tax adjustment under Art. 4.4.1. That lifts the rate to 14.6% and the top-up to €1.84M instead of €8.28M.

Which countries lose the safe harbour in 2026?

Two. Switzerland passes at 16.4% and Romania at 16.9% today, but the simplified test is 17% for years starting in 2026, and neither passes routine profits. Both would need the full calculation. On GloBE income both stay above 15%, so no top-up is expected.

Draft a note to the audit committee on FY2025 top-up tax

Draft ready: top-up tax for FY2025 is €3.12M, all paid locally (Ireland €1.84M, Singapore €0.80M, UAE €0.48M). 27 of 30 countries are in the transitional safe harbour. Nothing is due at the parent. Two countries are on the 2026 watch. Nothing is sent until you approve it.

What still stops us from filing?

Three things, in order. 7 elections need your signature: the safe harbour for 27 countries, the domestic top-up safe harbour for Ireland, Singapore and the UAE, and Ireland's five-year stock-based compensation election. Today's 4 proposed adjustments need accepting; you can accept them as you sign. And Daniel should explain the Poland CbC difference of €2.3M.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The ETR ladderEvery country a rung sorted by rate, the 15% line, safe-harbour badges, top-up tax, what needs the Head of Tax and the agents' work.
Agents at workThe plan first, then each agent's step in view: entities confirmed, missing values filled and pinned, tests run, top-up calculated.
One country, start to finishThe bridge from accounting profit to top-up tax with the article on every line, the Checker's separate run and the three tests.
Open any number at its sourceThe workpaper rows behind the deferred tax adjustment, the recast at 15%, the recapture test, who read it and when.
GloBE adjustmentsEvery adjustment with its amount, rate effect, article and guidance, source and the Checker's verdict, waiting for a person to decide.
Top-up taxExcess profit, rate gap and top-up for each country that fails every test, who collects it, the due date and the effect of today's adjustments.
Safe-harbour tests and the 2026 cliffDe minimis, simplified ETR and routine profits for every country with the numbers behind each, re-tested at next year's 17%.
The 268 return fieldsEvery field by section with its value, source, confidence and state — here the two filled from local controllers' replies.
The return, validated and tied outSections filled, the schema checks and the tie-out to the CbC report country by country, with Poland's difference to explain.
Sign the electionsSeven elections with their lock-in, signed by the Head of Tax with a reason code and a note, today's adjustments accepted with them.
Elections and approvalsEach election with the agent's recommendation, its effect, its evidence and the signature, time and reason code.
Audit trailEvery action by people and agents, in order and append-only, with the evidence pack to export for the auditor.
Your rulesMinimum rate, simplified ETR by year, de minimis, carve-out rates, rate-cliff warning, tie-out tolerance and when to ask a person.
Governance

Built for the signature and the audit: traced, re-performed, signed.

Every field pinned to its sourceEach of the 268 return fields records the document, the cell and the confidence it came from. Open any number and you land on the line behind it — a workpaper row, a CbC figure, a controller's reply.
Every adjustment cites its ruleThe Adjustment agent proposes each GloBE adjustment with its article and OECD guidance and its effect on the rate. It never accepts its own proposal; the Pillar Two Manager decides, and above €1M a second reviewer.
A second agent re-performs the workThe Checker recalculates every ETR and top-up from the sources in a separate run. When it disagrees it escalates to a person — it never averages, and it cannot clear its own flag.
The Head of Tax signs every electionAgents recommend; only the Head of Tax elects. Each election shows its lock-in — annual, five years, once out always out — its effect and its evidence, and is signed with a reason code that goes into section 4 of the return.
Nothing goes out half-approvedThe return is released only when every election is signed and every flag is explained. The Filing agent prepares the return, the local returns and the notifications, and never files.
A trail the auditor can testEvery action by people and agents is on an append-only audit trail, held for 10 years. The statutory auditor gets a read-only view of every number, source and signature, and an evidence pack to export.
Configuration

Your rules, set once

The rates and tolerances every country is tested against are settings. Changes are versioned and on the audit trail.

SettingDefaultChoose from
Minimum rate15%The line on the ladder
Simplified ETR test2025: 16% · 2026: 17%Set by fiscal year for the transitional CbC safe harbour
De minimis€10M revenue · €1M profitThresholds read from the CbC report
Substance carve-out ratesPayroll 9.6% · tangible assets 7.6%Transition rates by fiscal year
Rate-cliff warning1 ptUp or down in steps of 0.5 pt
CbC tie-out tolerance€0.5MUp or down in steps of €0.5M
Ask a person below85% confidenceUp or down in steps of 5 points
Adjustments needing a second reviewerAbove €1MAccepted by the Pillar Two Manager; a second reviewer above the limit
Connections

Works with the systems the return already draws on

General ledger and consolidationthe group ERP's 30 ledgers and the FY2025 consolidation
Country-by-country reportthe qualified CbC report behind every safe-harbour test
Tax provision workpaperscurrent and deferred tax and uncertain positions, by country
Payroll and fixed-asset registerpayroll and tangible assets for the substance carve-out
Legal-entity registerentities, ownership, status and tax numbers
Document store and emailworkpapers, evidence and the local controllers' replies
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of return fields traced to a source document and cell
268 of 268 fields
each pinned to its cell
estimated
€6.4M
of Irish top-up tax not overpaid once deferred tax is counted
Without the adjustment€8.28M
With it€1.84M
target
168days
before the filing deadline, the return complete
Ready 14 Oct
due 31 Mar 2027

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (OECD GloBE Model Rules Art. 8.1.6 — the return due 15 months after year end, 18 for the first year; OECD transitional safe harbours, Dec 2022, and the Side-by-Side package, Jan 2026; KPMG, “Pillar Two compliance: navigating the complexity”, 2025 — 200+ data points per entity; EY, Jun 2026 — nearly 40 countries required 2024 filings). Kestrel & Vane Group, its entities and the people named on this page are fictional — characters and sample data in the working solution.

Questions

What heads of tax ask us.

What is Pillar Two compliance software?

Software that proves a multinational group pays at least 15% in every country under the OECD global minimum tax: it collects the entity data, runs the safe-harbour tests, calculates top-up tax and prepares the GloBE Information Return and the local returns. Pillar Two Compliance does this with seven agents that pin all 268 return fields to their source, test every country, propose GloBE adjustments with the OECD rule for each, re-perform the results and tie the return to the CbC report. The Head of Tax signs every election before anything is filed.

How does it run the transitional CbC safe-harbour tests?

The Safe-harbour agent runs de minimis, simplified ETR and routine profits for every country from the qualified CbC report and the statutory accounts, with the numbers behind each test. It also tests the domestic top-up safe harbour and re-tests at next year's rate: in the demo, Switzerland at 16.4% and Romania at 16.9% pass at 16% but would fail at 17% in 2026.

How does it calculate top-up tax for a country that fails?

The Adjustment agent proposes the GloBE adjustments to income and covered taxes, each with its article and guidance, and a person accepts or rejects them. The Top-up calculator then works out the GloBE ETR, the substance carve-out at the transition rates, excess profit and top-up, and which country collects it. The Checker re-performs every figure in a separate run.

How does it get data from our local controllers?

For each missing value the Data agent writes to the named controller with the field definition and the source it expects, chases after 5 business days by default, and reads the reply back into the field with its pin. Below 85% confidence it asks a person instead of filling the value.

Does it tie the GloBE return to the CbC report?

Yes. The Checker ties revenue and profit in the return to the CbC report for every country and flags differences above the tolerance, €0.5M by default. In the demo 29 of 30 countries tie; Poland's €2.3M difference is an intragroup dividend, explained with a reason code before the return can be released.

Do people stay in control of elections and filing?

Yes. Agents propose and recommend; the Pillar Two Manager accepts adjustments, a second reviewer is needed above €1M, and only the Head of Tax signs elections, each with a reason code. The return is released only when every election is signed and every flag explained, and the Filing agent never files.

Can our auditor see the evidence?

Yes. The statutory auditor gets a read-only view of every number, source and signature, and the audit trail of people and agents is append-only and held for 10 years. An evidence pack can be exported for the auditor's working papers.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your entity register, CbC report, provision workpapers and last year's return — and it goes live once every quality gate has passed. A guided set-up confirms the group, the filing entity, the sources and the people; we will walk you through it on your own data first.

See it on
your entities.

We'll run Pillar Two Compliance on your own entity data — your CbC report, provision workpapers and last year's return.