Pillar Two Compliance Checklist: everything you need before your first GIR

The first GloBE Information Return (GIR) filing is the most operationally demanding compliance exercise most large MNE tax teams have ever run. The data requirements are broad, the computation is multi-layered, and the filing format is new. This checklist works through each phase in order, so nothing falls through the cracks.

Phase 1: scope and entity mapping

1. Confirm the group meets the €750 million consolidated revenue threshold in at least two of the four preceding years (Art. 1.1).
2. Identify all constituent entities (CEs) — including those excluded from consolidation — and map them to their jurisdictions.
3. Identify flow-through entities (Art. 3.5.1) and joint ventures (Art. 32.) that require separate treatment.
4. Confirm the ultimate parent entity (UPE) and any designated filing entity for GIR submission.
5. Record the fiscal year end for each jurisdiction — deadlines are calculated from this date.

Phase 2: data collection

1. Obtain the consolidation pack or trial balance per entity (GloBE Income source — Art. 3.1).
2. Obtain the tax provision per entity: current tax expense, deferred tax balances, statutory rates, UTPs (Adjusted Covered Taxes — Art. 4.1).
3. Prepare the adjustments schedule: excluded dividends (Art. 3.2.1(b)), stock-based compensation (Art. 3.2.2), pension adjustments, FX revaluations.
4. Prepare the SBIE schedule: eligible payroll costs and tangible asset net book values per entity (Art. 5.3.3).
5. Gather CbCR data if using the transitional safe harbour (Art. 9.1).
6. Confirm which jurisdictions have enacted a QDMTT and gather local tax data for those jurisdictions.

Phase 3: safe harbour pre-screening

1. Run the transitional CbCR safe harbour for each jurisdiction: de minimis, simplified ETR, and routine profits tests.
2. Document each test result and the qualifying route (or failure reason) for each jurisdiction.
3. Confirm the transitional ETR threshold: 15% for FY 2024, 16% for FY 2025, 17% for FY 2026+.
4. Apply QDMTT safe harbour where applicable — this removes the jurisdiction from the IIR computation entirely.

Phase 4: GloBE computation

1. Compute GloBE Income per entity: apply all Art. 3.2 adjustments to financial accounting net income.
2. Compute Adjusted Covered Taxes per entity: add current + deferred tax, recast deferred balances at 15%, apply Art. 4 adjustments.
3. Compute jurisdictional GloBE ETR: aggregate CE figures by jurisdiction, divide adjusted covered taxes by net GloBE income.
4. Compute SBIE carve-out per entity using the applicable-year payroll and tangible asset rates.
5. Compute top-up tax per jurisdiction: max(0, 15% − ETR) × (GloBE income − SBIE).
6. Allocate IIR top-up tax to the appropriate parent in the ownership chain.

Phase 5: GIR preparation and filing

1. Assemble all ~480 GIR data points per jurisdiction, cross-referencing each figure to its source.
2. Generate GIR XML to the OECD schema and validate against the published XSD before submission.
3. Submit an IIR notification (Art. 8.1.3) in each jurisdiction where IIR applies, by the required deadline.
4. File QDMTT self-assessments in relevant jurisdictions by their local deadlines.
5. Retain the full provenance trail — source data, calculation steps, digests — for at least the applicable limitation period.

Pillar2OS automates Phases 3–5 from your uploaded entity data and generates the GIR XML, obligation tracker, and provenance report in a single pass. Start with five entities free.