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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. 

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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. 

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Members-Only Tools

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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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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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Pillar Two Deferred Tax Liability Calculator

Deferred Tax has a significant impact on the Pillar Two effective tax rate (ETR) and therefore on any top-up tax that may be levied. Use our Pillar Two Deferred Tax Liability Calculator to model the impact on the Pillar Two top-up tax.

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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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Pillar Two Rapid Assessment Tool

Rapid Assessment Tool

Our Pillar Two Rapid Assessment Tool, simulates the impact of the Pillar Two GloBE Rules. It is a slimmed-down version of our Pillar Two Tax

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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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Latest Articles

Accounting standards and how they impact on Pillar Two

Pillar Two Accounting Disclosures Under IFRS

IAS 1, IAS 10 and IAS 12 all have provisions that can impact on the required disclosures in financial statements for Pillar Two, however, the key determinant will be whether the domestic tax law to implement the Pillar Two GloBE Rules has been announced, substantively enacted, or enacted before the financial statements are issued.

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Joint Statement – Pillar Two Gains Momentum in the EU

Germany, France, Italy, Spain and the Netherlands issued a joint statement stating that if agreement is not reached on Pillar Two in ‘the next few weeks’ they will push forward domestic implementation of the Pillar Two GloBE rules ‘by any possible legal means’ in 2023. 

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A Review of the Amount A Double Tax Relief Rules

The Amount A elimination of double taxation provisions in Title 5 of the Progress Report on Amount A of Pillar One apply to prevent a multinational group being taxed twice on profits allocated to a market jurisdiction where there is already some form or physical establishment that is subject to tax. 

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Estonia and the Pillar Two GloBE rules

Pillar Two GloBE Rules and Estonia’s Distribution Tax

A key issue with a distribution tax regime such as Estonia’s is that a company may not distribute profits for a number of years. They would have GloBE income but no or limited tax suffered on that income which would lead to a sizeable Pillar Two top-up tax liability. As such a distribution tax regime election is available.

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