The Pillar 2 Operating System.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.