The only Pillar Two Operating System

The Pillar 2 Operating System

Every figure in your GloBE Information Return traces, step by step, back to the source input - with the applied OECD rule cited at each step.

Free for 5 entities · No card required

480 GIR data points computed
OECD aligned & audit-ready
100 % of figures traceable

Click any figure.
See where it came from.

Every number in the GIR traces through a provenance graph back to its source data. No black boxes. No manual reconciliation.

Click any row to see the detailed calculation breakdown
LIVE TRACE Top-up Tax → Source
DETERMINATION Jurisdictional Top-up Tax - UK
EUR 947,600
DERIVED Top-up % = 15% − 10.0% ETR
5.00%
DERIVED Excess Profit = Income − SBIE
EUR 18,952,000
AGGREGATE Net GloBE Income - UK
EUR 20,000,000
SOURCE Revenue - Trading Subsidiary Ltd
EUR 100,000,000 trading-sub-tb.xlsx, row 12
SBIE Payroll + Asset carve-out
EUR 1,048,000
PRODUCT TOUR

Every capability, live — click a dot to jump straight there

app.pillar2os.com
LIVE DEMO
Pillar2OSpreparer@companya.com
Welcome, Bob
3 engagements · 12 entities · 8 jurisdictions
3Engagements
12Entities
8Jurisdictions
€2.1mTop-up Tax
CO-A-20242024
Company A Ltd
5 entities3 jurs87%
UKIEDE
CbCRPre-flightData loaded
CO-B-20242024
Company B plc
4 entities3 jurs64%
UKFRNL
CO-C-20242024
Company C Ltd
3 entities2 jurs42%
UKUS
Pillar2OSpreparer@companya.com
Pillar 2 Compliance
Reference guide - scope, safe harbours, rates, implementation tracker
FY 2024
OverviewSafe HarbourSBIE RatesImplementation TrackerGuidance
Minimum rate
15%
Global minimum
Scope threshold
€750m
Revenue, 2 of 4 years
Transitional period
FY 2027
CbCR safe harbour
GIR deadline
15 months
After fiscal year end
Art. 1.1
Scope

Revenue ≥ €750m in 2 of 4 preceding years

Art. 3.1–3.5
GloBE Income

FANIL + Art. 3.2 adjustments

Art. 4.1–4.6
Covered Taxes

Current + deferred (recast at 15%) + adjustments

Art. 5.3.3
SBIE Carve-out

Payroll 9.8% + assets 7.8% (FY 2024)

Pillar2OSSafe Harbour Eligibility - CO-A-2024How it works
3Jurisdictions
2Safe Harbour
1Full GloBE required
UKFull GloBE required
Revenue €100mPBT €20mETR 10.0%
De Minimis - Revenue €100m > €10m limit
Simplified ETR 10.0% below 15% threshold
Routine Profits €20m exceeds SBIE €1.05m
Trace lineage:
IESafe Harbour applies
Revenue €200mPBT €70mETR 25.0%
Simplified ETR 25.0% ≥ 15% - PASS
Qualified via: Simplified ETR
DESafe Harbour applies
Revenue €80mPBT €25mETR 25.0%
Simplified ETR 25.0% ≥ 15% - PASS
Qualified via: Simplified ETR
Pillar2OSCO-A-2024 · Data Collection
DATA COLLECTION
Upload your group's data
Choose one approach or use both
RECOMMENDED
Use our template
One file, all 7 data types
P&LTaxSBIEElectionsCbCRQDMTT
↓ Download Excel Template
Drop completed template
Upload what you have
Drop existing exports
Consolidation Pack / P&L
Drop or click to browse
Tax Provision
Drop or click to browse
Adjustments Schedule
Drop or click to browse
group-data-pack-2024.xlsxData Pack · 1.2 MB
312 rows across 5 entities
Pillar2OSCO-A-2024 · Calculation Breakdown
Result Summary - 5 entities · 3 jurisdictions
Total top-up tax€947,600digest: 7f3a2b9c...
EntityTypeStatusJur.ETRSBIEQDMTTTop-up Tax
Trading Sub Ltd CE Top-up due UK 10.00% €1,048k €947,600
Irish Holdings Ltd CE Safe harbour IE 25.00% €0
German GmbH CE Safe harbour DE 25.00% €0
Flow-through LLC Flow-through Art. 3.5.1 -excluded UK €0
TechCo JV (50%) JV Art. 32. JV allocation UK 18.00% €0
Financial accounting net income+€22,500,000ENT.FIN_INCOME
Excluded Dividends (Art. 3.2.1(b))−€2,000,000ENT.ADJ.EXCL_DIV
SBC Adjustment (Art. 3.2.2)−€500,000ENT.ADJ.SBC
= GloBE Income€20,000,000ENT.GLOBE_INCOME
Current Tax Expense+€1,500,000ENT.CURR_TAX
Deferred Tax (recast to 15%)+€500,000ENT.DEF_TAX_RECAST
= Adjusted Covered Taxes€2,000,000ENT.ADJ_COV_TAX
GloBE ETR10.00%JUR.GLOBE_ETR
Payroll carve-out (9.8% × €8,000k)€784,000ENT.SBIE.PAY
Asset carve-out (7.8% × €3,387k)€264,000ENT.SBIE.ASSET
= SBIE Carve-out€1,048,000JUR.SBIE
Top-up % = max(0, 15% − 10.00%)5.00%JUR.TOPUP_PCT
Excess Profit (€20,000k − €1,048k)€18,952,000JUR.EXCESS_PROFIT
= Jurisdictional Top-up Tax€947,600JUR.TOPUP_TAX
Art. 3.5.1 -Transparent Entity 100% owned by: Trading Sub Ltd  ·  Income and tax reallocated to direct owner
Financial accounting net income€3,200,000ENT.FIN_INCOME
Art. 3.5.1 -Fully group-owned transparent entityGloBE Income = €0ENT.FLOW_THROUGH
Income allocated up to direct owner (Trading Sub Ltd)€3,200,000 ↑ENT.FT_ALLOC
Owner's covered taxes increased by this entity's tax€640,000 ↑ENT.FT_TAX_REALLOC
Top-up tax contribution at entity level€0ENT.TOPUP_CONTRIB
Art. 32. - Joint Venture · 50% owned by Company A Ltd Separate Pillar 2 computation · results allocated at ownership %
Full entity GloBE Income€8,000,000JV.GLOBE_INCOME
50% ownership attribution to Company A Ltd€4,000,000JV.ATTR_INCOME
Full entity Adjusted Covered Taxes€1,440,000JV.ADJ_COV_TAX
50% ownership attribution€720,000JV.ATTR_TAX
JV GloBE ETR (€720k ÷ €4,000k)18.00%JV.GLOBE_ETR
Top-up % = max(0, 15% − 18.00%)0.00%JV.TOPUP_PCT
= JV Top-up Tax allocated to parent€0JV.TOPUP_TAX
Pillar2OSProvenance Trace · Top-up Tax → Source
Every figure traces back to its source. Tamper-evident digests on every node.
DETERMINATIONJurisdictional Top-up Tax - UKEUR 947,600JUR.TOPUP_TAX · v2024.1
DERIVEDTop-up % = max(0, 15% − 10.0% ETR)5.00%JUR.TOPUP_PCT · v2024.1
DERIVEDExcess Profit = GloBE Income − SBIEEUR 18,952,000JUR.EXCESS_PROFIT · v2024.1
AGGREGATENet GloBE Income - UKEUR 20,000,000JUR.NET_GLOBE_INC · v2024.1
DERIVEDFinancial accounting net income - Trading Subsidiary LtdEUR 20,000,000ENT.FIN_INCOME · v2024.1
SOURCERevenue - Trading Subsidiary LtdEUR 100,000,000trading-sub-tb.xlsx · row 12 · TB.ROWDigest: 7f3a2b9c1d4e8f2a...
DERIVEDSBIE Carve-out - Trading Subsidiary LtdEUR 1,048,000ENT.SBIE · v2024.1
Pillar2OSpreparer@companya.com
Filing Obligation Tracker
CO-A-2024 · Auto-generated from entity footprint · FY 2024
1Overdue
3Due ≤30 days
4Upcoming
8Total
OVERDUE
UKGloBE Information Return30 Jun 20263 days overdueNot started
DUE WITHIN 30 DAYS
UKIIR Notification (Art. 8.1.3)15 Jul 202620 daysIn progress
IEIIR Notification (Art. 8.1.3)20 Jul 202625 daysNot started
DEIIR Notification (Art. 8.1.3)31 Jul 202636 daysNot started
UPCOMING
UKQDMTT Self-Assessment31 Dec 2026158 daysNot started
IEGloBE Information Return30 Jun 2027339 daysNot started
Pillar2OSpreparer@companya.com
Team · CO-A-2024
3 members · 1 active review · multi-org collaboration
PB
Patricia B.
Lead preparer · Company A
Active
RK
Raj K.
Tax reviewer · Company A
Reviewing
SL
Sarah L.
Senior partner · Tax Firm B
Approver
RK
Raj K. flagged a query on Trading Sub ETR
@Patricia B. — can you confirm the deferred tax recast figure? The €500k looks off vs. the provision.
2 hours ago · UK · Trading Sub Ltd
PB
Patricia B. replied
Confirmed — the €500k is the DTA recast from year-end provision. Uploading revised schedule now.
1 hour ago
SL
Sarah L. approved the UK calculation
Approved · UK · ETR 10.00% · Top-up €947,600
Just now · UK · Trading Sub Ltd
ENGAGEMENT HUB Your Pillar 2 workspace — every engagement, every team at a glance

See a real
GloBE computation

Upload demo data, browse the jurisdiction ETR table, inspect the provenance trace, and download a formal GIR paper - all without signing up.

Welcome to Sandbox Northwind Group · FY 2024 · 3 jurisdictions
GBNorthwind Trading Ltd GBNorthwind Services Ltd IENorthwind IP Holdings Ltd DENorthwind Logistics GmbH
Jurisdiction ETR Top-up Tax Status
GB United Kingdom 16.67% Safe harbour
IE Ireland 12.00% €450k Top-up due
DE Germany 30.00% Safe harbour
Run the sandbox →

Everything Pillar 2 demands.
Nothing it doesn't.

Four artefacts in. Full GIR out. Every intermediate figure traceable to source.

Click-through provenance

Every GIR figure is clickable. Trace any number back through every calculation step to the source input that produced it, with the OECD rule cited at each point.

Safe harbour first

Pre-flight qualification checks, then de minimis, simplified ETR, and routine profits tests. Qualifying jurisdictions skip to zero - no wasted computation.

GIR XML export

Generate the OECD-schema-aligned GloBE Information Return as XML for filing. Plus a full audit report with every provenance trace.

Upload, don't re-key

Four artefacts per entity: consolidation pack, tax provision, adjustments schedule, SBIE schedule. Upload once, reuse mappings yearly.

Tamper-evident

Merkle-style digests on every node. Same inputs, same hash. Change one figure and the entire chain produces new digests. Audit-ready by design.

Real-time dashboard

ETR by jurisdiction, data completeness, top-up tax exposure - all at a glance. The view that goes in partner reviews and board packs.

Templates, guides & more

Free Pillar Two templates, data collection guides, and GloBE reference material — all in one place.

Go to Resources

Four artefacts in.
Full GIR out.

The complete input set for a GloBE computation. Everything else is a derivation.

01

Reporting Pack

Entity-level P&L and balance sheet data from the group reporting pack. Revenue, net income, FANIL — the financial accounting starting point for GloBE Income.

Art. 3.1 - GloBE Income
02

Tax Provision

Current tax, deferred tax proof, temporary differences, UTPs, statutory rates. The covered taxes source artefact.

Art. 4.1 - Covered Taxes
03

Adjustments Schedule

Excluded dividends, SBC, pensions, FX, revaluations - the Art. 3.2 memo items the TB can't supply.

Art. 3.2 - Adjustments
04

SBIE Schedule

Eligible payroll costs and tangible asset carrying values. Transitional carve-out rates applied automatically.

Art. 5.3.3 - SBIE
= Complete GIR with ~480 data points, every one traceable to source

Built for
sensitive data

Designed for the security requirements of large MNE groups and Big 4 tax advisory firms.

Tenant isolation

Every record scoped to an org ID. Enforced at the data layer, not just the API.

Versioned rules

OECD guidance changes are new rule versions. Re-run prior periods and diff what moved.

Immutable sources

Source data rows are never edited. Corrections are new rows. Append-only by design.

Audit-ready export

One-click GIR XML + full provenance audit report. Every figure, every rule citation, every digest.

Results from
Private Beta

What early users say about running their first GloBE computation on Pillar2OS.

We replaced three weeks of manual Excel with a single upload. The first time our external auditors asked to see workings, we just sent them the provenance report - they had no follow-up questions.

A
Beta user A
Group Tax Director · FTSE 250 industrials group

The safe harbour pre-check alone saves us significant time. Seven of our client's twelve jurisdictions qualified - we only ran full GloBE calculations where they were actually needed.

B
Beta user B
Senior Tax Manager · Big 4 advisory

I showed the ETR dashboard to our CFO in the first week. She immediately understood the exposure by jurisdiction. That conversation used to take two days of prep. Now it takes five minutes.

C
Beta user C
Head of Group Tax · UK-listed technology company

Build your AI compliance team

Purpose-built AI agents for Pillar Two. Each agent is trained on OECD GloBE Model Rules, your entity data, and your firm's workflow. Try any agent before you commit.

⚖️
Pillar Two Specialist
GloBE & Compliance Expert

Deep technical expertise across the GloBE Model Rules — ETR calculations, safe harbour tests, SBIE carve-outs, and GIR preparation. Ask it anything about Pillar Two.

GloBE calculations Safe harbour GIR assistance
Add to package →
🗂️
Personal Assistant
Operations & Admin

Handles the administrative layer — drafting client emails, scheduling, meeting summaries, and action tracking. Everything requiring sign-off comes to you for approval before it sends.

Email drafting Scheduling Action tracking
Add to package →
🔔
Compliance Monitor
Regulatory Alerts

Watches OECD channels, domestic tax authority announcements, and peer commentary 24/7. Alerts you when something changes that affects your active filing positions — with an impact assessment, not just a link.

OECD guidance Alert & impact Jurisdiction watch
Add to package →
🌍
Regulatory Tracker
Jurisdiction Intelligence

Maps the Pillar Two legislative landscape across 60+ jurisdictions — IIR, QDMTT, UTPR status, effective dates, filing deadlines, and domestic guidance — updated as legislation progresses.

IIR / QDMTT / UTPR 60+ jurisdictions Effective dates
Add to package →
📊
Data Coach
Data Preparation

Guides your team through data collection — mapping trial balance accounts to GloBE categories, identifying gaps in your tax provision or SBIE schedule, and catching anomalies before they reach the engine.

TB mapping Gap analysis Quality checks
Add to package →
🛡️
Safe Harbour Analyst
CbCR Safe Harbour Specialist

Assesses all three Transitional CbCR Safe Harbour tests per jurisdiction — de minimis, simplified ETR, and routine profits — and produces a heatmap of pass/borderline/fail before you run a single GloBE calculation.

De minimis test Simplified ETR QDMTT safe harbour
Add to package →

Pillar Two compliance - common questions

Everything MNE tax teams and advisors ask before adopting Pillar 2 software.

What is the best Pillar Two software?

Pillar2OS is built from the ground up for Pillar Two — not adapted from a broader tax platform. It combines a full GloBE calculation engine (ETR, SBIE, top-up tax, safe harbour tests), a filing obligation tracker, GIR XML export, and a tamper-evident provenance trace in a single platform. Unlike generic tax tools or spreadsheet models, every figure traces back to its source input with the OECD rule cited at each step — an audit trail that satisfies external auditors without follow-up questions.

Which companies need Pillar Two compliance?

Pillar Two applies to multinational enterprise (MNE) groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years. This covers thousands of large MNE groups worldwide. Tax advisory firms — Big 4, mid-tier and specialist boutiques — supporting those clients also need full GloBE calculation capability to advise, prepare and review filings on their behalf.

What data is required for Pillar Two?

Four artefacts feed the GloBE computation: a Reporting Pack (entity-level P&L and balance sheet data — source of GloBE Income under Art. 3.1); a Tax Provision (current tax, deferred tax, statutory rates — Adjusted Covered Taxes under Art. 4.1); an Adjustments Schedule (excluded dividends, stock-based compensation, pension, FX and revaluations — the Art. 3.2 memo items that require separate capture); and an SBIE Schedule (eligible payroll costs and tangible asset carrying values for the substance-based income exclusion under Art. 5.3.3). Pillar2OS accepts these as Excel or CSV uploads, or via a single standard template that consolidates all four.

How do companies calculate Pillar Two taxes?

The GloBE calculation follows four steps per constituent entity: (1) compute GloBE Income — start from financial accounting net income and apply the Art. 3.2 adjustments; (2) compute Adjusted Covered Taxes — add current and deferred tax, recast deferred balances at 15%, and apply Art. 4 adjustments; (3) compute the GloBE ETR — divide Adjusted Covered Taxes by GloBE Income; (4) if the ETR is below 15%, compute Top-up Tax — apply the top-up percentage to excess profit after the SBIE carve-out. Pillar2OS runs all four steps automatically from your uploaded data, with every intermediate figure stored as a provenance node.

What is a GloBE Information Return (GIR)?

The GloBE Information Return (GIR) is the standardised filing document required under Pillar Two, containing around 480 data points per jurisdiction — GloBE ETR calculations, top-up tax determinations, safe harbour test results, SBIE carve-out figures and entity-level constituent data. It must be submitted by the ultimate parent entity or a designated filing entity, generally within 15–18 months of the fiscal year end. Pillar2OS generates a complete, audit-ready GIR with every figure traceable to its source input and the OECD rule applied at each step.

How does Pillar2OS automate the GIR?

Pillar2OS builds the GIR directly from your uploaded entity data — no manual assembly required. Upload your consolidation pack, tax provision, adjustments schedule and SBIE schedule; the engine runs the full GloBE calculation and produces a complete GIR covering all 480+ data points. Every field in the return links to the calculation step and source row that produced it, so preparers can review and auditors can verify without requesting further workings.

Can Pillar2OS generate OECD GIR XML?

Yes. Pillar2OS exports the GloBE Information Return as OECD-schema-aligned XML, ready for submission to tax authorities that accept the standardised electronic format. The XML is generated from the same provenance graph as the on-screen figures — a change to any input produces a consistent change in both the visual review output and the XML file, with no separate reconciliation step required.

How does Pillar2OS maintain a full audit trail?

Every figure in Pillar2OS is emitted as a provenance node at the point of calculation — there is no separate reconstruction step. Each node carries the OECD article applied, the input values used, and a tamper-evident digest. The same inputs always produce the same hash: change one figure and the entire chain produces new digests. The full provenance tree can be exported as a PDF audit report for external auditors or tax authorities.

Can Pillar2OS track filing deadlines?

Yes. The Filing Obligation Tracker automatically generates a list of obligations — GIR filings, IIR notifications (Art. 8.1.3) and QDMTT self-assessments — derived from your entity footprint and the enacted rules in each jurisdiction. Obligations are colour-coded by urgency: overdue, due within 30 days and upcoming. Each entry shows the due date, days remaining and current status, so nothing falls through the cracks across a multi-jurisdiction engagement.

Why use Pillar2OS instead of spreadsheets?

Spreadsheet-based Pillar Two models break down at scale: formulas are opaque, version control is manual, and there is no audit trail linking a GIR figure to the source data that produced it. Pillar2OS replaces that entire stack with a single platform that handles data ingestion, GloBE computation, safe harbour testing, GIR preparation and filing obligation tracking — and produces a tamper-evident provenance trace for every output. External auditors receive a report they can verify independently, without follow-up questions.

Ready to trace
every figure?

Free to start — five entities, no card required.

Try free - 5 entities