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 ↓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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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.
Estimated split for one year's GloBE return of a group with about 200 entities in 30 countries, by hand and with the solution.
Seven specialist agents test every country, pin every field and calculate the top-up tax; the Head of Tax signs every election.
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.
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.”
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.”
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.
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.”
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.”
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.”
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.
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.”
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.”
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.”
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.
Seven specialist agents test every country, pin every field and calculate the top-up tax; the Head of Tax signs every election.
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.
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.
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.
Proposes GloBE adjustments to income and covered taxes, each with its amount, article, OECD guidance paragraph, source, confidence and effect on the rate.
Calculates the GloBE ETR, the substance carve-out at the transition rates, excess profit, top-up tax and which country collects it.
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.
Assembles the GloBE Information Return, validates it against the OECD schema, prepares the local returns and notifications and keeps the filing calendar.
Signs every election. The agents propose; a named person decides.
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.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rates and tolerances every country is tested against are settings. Changes are versioned and on the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Minimum rate | 15% | The line on the ladder |
| Simplified ETR test | 2025: 16% · 2026: 17% | Set by fiscal year for the transitional CbC safe harbour |
| De minimis | €10M revenue · €1M profit | Thresholds read from the CbC report |
| Substance carve-out rates | Payroll 9.6% · tangible assets 7.6% | Transition rates by fiscal year |
| Rate-cliff warning | 1 pt | Up or down in steps of 0.5 pt |
| CbC tie-out tolerance | €0.5M | Up or down in steps of €0.5M |
| Ask a person below | 85% confidence | Up or down in steps of 5 points |
| Adjustments needing a second reviewer | Above €1M | Accepted by the Pillar Two Manager; a second reviewer above the limit |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“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.
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.
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.
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.
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.
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.
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.
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.
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.
Every invoice checked before it leaves, and every rejection fixed the same day.
1-min demoTransfer Pricing DocumentationEvery margin tested before the year closes, and every file ready inside 30 days.
1-min demoTax Provision AutomationEvery rate reconciliation line tested against the 5% rule, tied to its workpaper.
1-min demoWe'll run Pillar Two Compliance on your own entity data — your CbC report, provision workpapers and last year's return.