Pillar Two Tax Engine

Cloud-Based Software for Unrivalled Pillar Two Analytics and Insights

Our cloud-based Pillar Two software provides access to market-leading analysis and insights to allow you to model the impact of the Pillar Two GloBE Rules on any potential top-up tax liability, determine best and worst case scenarios and simulate the impact of making various Pillar Two elections.

Pillar One Modelling Tool

Software to Model Profit Reallocation under Pillar One

Our Pillar One Modelling Tool provides a calculation of the estimated profits reallocated to jurisdictions under Amount A of Pillar One and the estimated corporate income tax on those reallocated profits. 

Given Pillar One feeds directly into Pillar Two, it also estimates the Pillar Two top-up tax liability after the application of Pillar One. 

Free access for site members. 

image showing a pie chart from the OECD Pillar One Modelling Tool

Latest Members Tools

Blended CFCI mage

Blended CFC Calculator

For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regime. Use our simple calculator.

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IIR Calculator

Income Inclusion Rule Calculator

Use our members Income Inclusion Rule Calculator to see how the IIR applies. Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company. 

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image showing multinationals and tax

UK Multinational Top-Up Tax Calculator

The UK published draft legislation on July 20, 2022, to implement a ‘multinational top-up tax’ in line with Pillar Two of the OECDs Two-Pillar Solution. We have produced a calculator to illustrate the key aspects to the calculation of the multinational top-up tax.

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under-tax payments rule calculator

UTPR Calculator

This Pillar Two under-taxed payments rule (UTPR) calculator gives an indication of the broad operation of how the top-up tax is allocated to UTPR jurisdictions.

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CFC pushdown calculator

CFC Pushdown Limitation Tool

When allocating taxes to group entities for the purpose of the Pillar Two rules, tax paid by a parent entity under a controlled foreign company (CFC) regime is usually allocated to the CFC entity. However, under Pillar Two, this is subject to a limitation. Use our interactive tool to see the impact of the CFC pushdown limitation.

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QDMTT Design Features

Pillar One Profit Allocation Calculator

On July 11, 2022, the OECD released a progress report on its Two Pillar Solution. This included draft rules on Pillar One. Whilst these draft rules are subject to a consultation, they nevertheless make interesting reading, particularly as there has, to date, been very little detailed information on the marketing and distribution profits safe harbour. Use our Pillar One profit allocation calculator to see the impact of the profit reallocation and marketing and distribution profits safe harbour.

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image showing 'pillar two deferred tax asset calculator'

Pillar Two Deferred Tax Asset Calculator

Deferred Tax is a key element of the Pillar Two Rules, aimed at smoothing out the effective tax rate to address timing differences. This simple Pillar Two deferred tax calculator shows the broad operation of a deferred tax asset and its impact on the effective tax rate and top-up tax.

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