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.
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.
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.
Calculate estimated GloBE top-up tax. Add unlimited companies and jurisdictions via an easy to use control panel to view potential jurisdictional liabilities.
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide a drill down into some of the key metrics and data sources that are relevant for Pillar Two on a jurisdictional basis.
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.
Our Global Digital Services Tax Tracker has been updated to January 23, 2023.
Our members-only modelling tool carries out the calculations based on the required inputted information to determine whether the Transitional CbCR Safe Harbour applies.
Our Global VAT on Digital Services Tracker has been updated and now covers over 80 jurisdictions.
Use our global assessment tool to determine the VAT position on the provision of international digital services. The tool is fully cited to the relevant domestic law.
Use our Global map to determine the effective tax rate for R&D expenditure globally. Including the average R&D ETR per jurisdiction and the impact of incentives.
Global intellectual property (IP) incentives have grown in recent years. Use our tool to compare different regimes.
This Modelling Tool accompanies our analysis Modelling the Impact of Payroll Tax Incentives Post Pillar 2. Members use this tool to adjust key variables.
The Subject-to-Tax Rule is a key component of Pillar Two, and unlike the GloBE Rules focuses on source jurisdictions. Our members-only global map highlights domestic withholding taxes at less than the 9% rate under the Subject-to-Tax Rule.
For Pillar Two purposes, investments in fixed assets can involve an interaction between deferred tax impacts and the the substance-based income exclusion.
Our interactive map covers the current global treatment of VAT on digital services. Fully cited with links to relevant laws.
Our interactive map breaks down worldwide corporate income tax rates to identify jurisdictions with a headline CIT rate below the Pillar Two 15% rate.
Our Global Digital Services Tax Tracker allows you to stay up to date with international digital service taxes. Cited and with links to domestic legislation.
Our OECD Pillar One Modelling Tool is designed to provide an analysis of the high-level impact of Amount A of Pillar One.
Our Investment Companies Top-Up Tax Calculator models the impact of Pillar Two in a jurisdiction where there are a mix of investment and non-investment companies.
The Revenue Sourcing Rules for Amount A are used to determine where an in-scope multinational group derives its revenues. This is then used in the profit reallocation calculation.
Use our interactive tool to quickly determine the relevant sourcing rule for each revenue type.
Our GloBE Loss Election interactive tool allows you simulate the impact on your top-up tax liability depending on whether a GloBE Loss Election is made or not.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
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