Image showing the logo

Access Our Pillar Two Tax Engine

Cloud-based software for advanced Pillar Two analytics and insights. 

Our Pillar Two Tax Engine allows you to model the impact of the Pillar Two GloBE Rules and any top-up tax liability, determine best and worst-case scenarios and simulate the impact of making various GloBE elections. 

Read More

Pillar two tax engine

Access our Pillar One Modelling Tool

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. 

Read More 

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

Latest Articles

QDMTT Legislative Tracker

QDMTT: Legislative Tracker

Track the development and application of QDMTTs as they are implemented globally. The OECD Administrative Guidance provides significant flexibility as to their design.

Read More »
commercial property

Investment Property & The GloBE Rules

Whilst the treatment of investment property for financial accounting purposes is important when determining the GloBE treatment, of even more importance are any differences between the financial accounting treatment and the domestic tax treatment.

Read More »
Joint Ventures and Pillar Two

Joint Ventures and the Allocation of Pillar Two Top-Up Tax

The Pillar Two rules include specific rules for Joint Ventures (JVs) that would otherwise not be within the scope of Pillar Two due to not being consolidated in the financial accounts of the MNE group. However, of more interest is how the amount of top-tax tax (and by implication the amount not collected) varies depending on the JV group structure. Read more in this article.

Read More »
image showing the world with flags in certain places to illustrate permanent establishments under pillar two

Domestic Implementation of the GloBE Rules: Differing Approaches

A number of jurisdictions have issued legislation (either draft or enacted) to implement the Pillar Two GloBE Rules, however, the approach taken differs significantly. In this article we look at domestic differences not only from the OECD Model Rules, but differences in the implementation of the rules between jurisdictions.

Read More »

Members-Only 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.

Read More »

Updated Pillar 2 Modelling Tool – OECD CbC Data

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. 

Read More »
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. 

Read More »