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
350+
M2M transmissions
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 was GIR notifications and self-assessment returns, not the GIR itself.
“It 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.
Canada alone accounted for a quarter of the season’s filings. The five leading jurisdictions together made up just under half of everything filed, while the remaining 29 shared the rest between them.
Top filing jurisdictions
Top five jurisdictionsAll other jurisdictions, combined
Bars are scaled to Canada, the season’s largest jurisdiction; the figure beside each name is its actual share of total filings.
25.1%
Canada alone — the season’s largest jurisdiction
48.9%
Top five jurisdictions, combined
51.1%
Spread across 29 other jurisdictions
Filing season · totals
1,700+
Filings prepared across the season
34
Jurisdictions with at least one filing
30.5%
Created in the final week of the season
6
Form types filed through the platform
The mix ran from GIR notifications and the GloBE Information Return itself to registrations, self-assessment returns, and QDMTT and IIR top-up-tax returns.
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Ahead: four filing seasons compared, GIR amendments, the benchmark, and what comes next.
Direct to tax authorities
350+ returns sent machine-to-machine.
Where an authority opened a direct channel, returns went straight from the platform into its systems — no portal, no manual upload. Five jurisdictions accepted returns machine-to-machine this season, and three quarters of every transmission was bound for Canada or the United Kingdom.
M2M transmission share by country
Live transmission channelChannel in progress
Bars are scaled to Canada, the largest channel; the figure beside each country is its share of all machine-to-machine transmissions.
350+
Returns transmitted direct to tax authorities
21%
Of all season filings sent machine-to-machine
75.4%
Went to Canada and the United Kingdom
Transmission channels · season
5
Jurisdictions with a live M2M channel
1
Further channel in progress — Australia
Switzerland and Italy filed at volume with no direct transmission channel this season, so their returns moved through local channels instead.
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
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
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
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
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
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
+
Global Filing Visibility
+
XatBot AI
+
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
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.
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The First Pillar Two Filing Report
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