Inside the First Pillar Two Filing Season: Trends, Challenges, and Lessons

Australian CGDMTR Filing: Building a Repeatable Pillar Two Process with Direct ATO Transmission

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Inside the First Pillar Two Filing Season: Trends, Challenges, and Lessons

Australian CGDMTR Filing: Building a Repeatable Pillar Two Process with Direct ATO Transmission

Get started Book a demo

The First Pillar Two Filing Report

Proven at scale.

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P2
Jun 2026 · Global Minimum Tax Journey
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The First Pillar Two Filing Report

Proven
at scale.

The first major global Pillar Two filing season moved multinational tax teams from preparation into execution.

1,700+
filings
34
jurisdictions
The season · Jun 2026

From preparation into execution.

More than 1,700 Pillar Two filings were prepared or submitted across 34 identified jurisdictions. Pillar Two is no longer only a technical challenge, it is a recurring global compliance process.

Beyond a single global return

Compliance extended far beyond the GIR.

60%+
of recorded filing activity consisted of GIR notifications and self-assessment returns rather than GloBE Information Returns.
“The filing season evolved into a complex network of registrations, notifications, top-up tax returns and local GIRs, with practices varying significantly across jurisdictions.”
Jacob Fulton, Head of Quantitative Tax Practice, Orbitax
The 30 June compression

Nearly a third of filings landed in the final week.

~30%
of all filings
Created in the final seven days before 30 June
Rest of the seasonFinal week

GIR notifications and self-assessment returns represented almost two-thirds of the filing types created in that week. More than a third of activity landed in the final week in:

Select a jurisdiction to see how its final week broke down.
42%
Netherlands
Share of the jurisdiction's filings created in the final seven days
Led by GIR notifications
A distributed filing landscape

Activity across 34 jurisdictions.

Five highest-volume jurisdictions
Canada
United Kingdom
Germany
Netherlands
Ireland
Bars show relative rank, not exact share.
38%
Canada + UK
52%
Top five of the season
33%
Outside the top ten
The teams behind the numbers

Pillar Two in Practice

Volume is one way to read the season. The other is to look at individual groups. Select a company to read its season.

Technology · NYSE listed · clients in 50+ countries
A scope problem before a filing problem.

Two months from the deadline, EPAM’s tax team did not yet have a full picture of how many jurisdictions it needed to report in, or which filing types applied where. Hungary, its designated GIR filing location, released API protocols and its filing gateway only weeks before the deadline.

The team used XatBot to build an initial view of its global obligations, then worked the season from a single jurisdiction-by-jurisdiction forms library. Nearly all FY2024 filings across 27 countries were complete by the time of interview.

“Without that structured view across all the countries, I would have felt lost in the updates and the details. Twenty-seven countries is not something I could have tracked on my own.”
Laszlo Icsu
Senior Director, Head of Tax Europe, APAC & CEE, EPAM Systems
Apparel and footwear · Portland, Oregon
The calculations were done. The filing was not.

Columbia Sportswear’s original Pillar Two software supported the calculation but offered no way to prepare, validate and submit the GloBE Information Return. Filing would have meant a manual process or a local advisor.

The team moved the work into Orbitax, completed the Canadian registration requirements, and transmitted its FY2024 GIR to the Canada Revenue Agency. It was accepted approximately ten days after the calculations were finished.

“We were comfortable with the calculations. The difficult part was getting from the numbers to a return the tax authority would actually accept.”
Scott Rice
Senior Director, International Tax, Columbia Sportswear
Semiconductors · with Advance Tax Compliance
Filing first, with no playbook to follow.

NXP chose to complete its Pillar Two filings in-house rather than outsource them, on the reasoning that the team already owned the rules, the forecasting and the tax provision. What it needed was a way to push structured data into XML and PDF returns, with validation before submission.

Working alongside Advance Tax Compliance and the Dutch Tax Administration, the project produced the first successful machine-to-machine GloBE Information Return submission in the Netherlands.

“It was a pleasure and unique experience to work together with them to overcome the electronic filing challenges and successfully validating our compliance strategy.”
Cees Boomhouwer
Head of Tax Accounting, NXP Semiconductors
Tax advisory · with Thomson Reuters
One client obligation could have gone to the Big Four.

A Swiss subsidiary put one of MJ Associates' clients in scope for its first GloBE Information Return. With roughly five weeks to the deadline, the boutique firm wanted to keep the engagement in-house rather than refer it out.

Already using Thomson Reuters GoSystem, MJ Associates adopted Global Minimum Tax through Thomson Reuters supporting the filing.

“We cannot quantify the number of hours saved. All we can say is that at the end of the day, we got it filed in far, far less time than it would have taken had we tried to do it ourselves.”
Shelly Garcia
Partner, MJ Associates
From technical knowledge to filing infrastructure

A knowledge problem ends when the answer is correct. An infrastructure problem then begins.

More than 1,700 successful filings required more than correct calculations. In some jurisdictions, filings transmitted directly to the authority; in others, the platform generated authority-ready output for a government portal. The method differed by country, the need for a structured way to manage obligations did not.

CbC Compliance & Reporting · Global Minimum Tax

The filing requirement starts with data you already filed.

Orbitax reads the CbCR XML, or the US Form 1120 XML for a US-parented group, and automatically identifies the entities in scope, determines which jurisdictions qualify for the CbCR Safe Harbour, and then performs only the calculations that remain.

Upload what you already filed
A filed CbCR XML, a US Form 1120 XML for US-parented groups, or Safe Harbour data carried straight across from an existing CbC Scenario. No new data collection to begin.
One source of truth

CbC, Australian Public CbC, EU Public CbC, and Pillar Two all use the same underlying data, ensuring consistent numbers across every filing. Read the announcement

Fewer calculations, not fewer checks

Qualifying for the CbCR Safe Harbour eliminates unnecessary calculations, while the Safe Harbour assessment and supporting data remain fully documented.

AI-Powered Filing Support

Every Filing Makes the Platform Smarter

“
Every support question, validation error and successful submission made the platform smarter. The goal was not simply to answer questions, but to ensure that every lesson learned became guidance available to every customer through XatBot.
Bianca Kuijper
Bianca Kuijper
Chief Operating Officer, Orbitax
A growing body of operational knowledge

A season of lessons, built in.

The first filing season created more than completed returns. It created practical knowledge. Orbitax captures those lessons and embeds them into workflows, validations, filing guidance and XatBot AI, allowing every customer to benefit from the collective experience.

Jurisdiction-specific workflows −
The first filing season revealed that filing requirements extend beyond tax rules. Authority portals, submission methods, and local procedures are continuously embedded into jurisdiction-specific workflows as they evolve.
Validation logic +
The first filing season revealed how different tax authorities validate returns in practice. Those jurisdiction-specific validation patterns are now built into Orbitax, reducing avoidable filing errors before submission.
Global Filing Visibility +
Orbitax maps the 174 available Pillar Two forms to your filing footprint, showing only the obligations relevant to your group. A single compliance grid tracks the status of every required filing across all jurisdictions.
XatBot AI +
The first filing season revealed the questions tax teams asked most often. XatBot now answers them in context, explaining validation checks, resolving filing issues, and helping determine jurisdiction-specific filing obligations before work begins.
GIR amendments · Filing Manager

Need to file an amendment?

An accepted GIR filing can now be amended in the Orbitax Filing Manager, corrections, deletions and inclusions of new records, through a guided Export & Transmit wizard.

Amendments
Flag corrections, deletions and new records against the accepted GIR. Orbitax tracks each change against the OECD amendment schema.
The OECD split rule

One amended submission carries either new records or corrections and deletions, never both. An amendment that does both is split in two and submitted in sequence.

Two records, on demand

Download the Merged Record, the full filing the authority will hold, or the Amendment Record, just the changed sections.

The Pillar Two Benchmark · interactive

Where does your team stand?

Four questions, measured against the 1,700+ returns filed across 34 jurisdictions this season.

Consolidated group revenue
Jurisdictions in scope
Where your team is now
Your CbCR data

Choose your jurisdictions and current stage to see your position against the season.

Your obligation footprint
—

estimated discrete obligations: registrations, notifications, QDMTT and IIR returns and local GIRs, not the GIR alone.

Ahead of — of teams tracked this season

CbCR Safe Harbour route
Walk through your footprint
Operationalizing International Tax

Filed is not final

The first filing season was about getting returns filed. The next is about making the process repeatable. As Pillar Two expands, tax teams will increasingly focus on standardized workflows, shared data, and operational consistency across jurisdictions.

Stronger validations
Jurisdiction-specific rules, hardened by the season's questions.
Direct transmission
Extended where authorities provide the necessary interfaces.
Thank you, see you in Issue 02.
Unify. Simplify. Empower.
The First Pillar Two Filing Report
Proven at scale.
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