The First Pillar Two Filing Report
Proven at scale.
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Proven
at scale.
The first major global Pillar Two filing season moved multinational tax teams from preparation into execution.
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.
Compliance extended far beyond the GIR.
Nearly a third of filings landed in the final 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:
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.
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Ahead: four filing seasons compared, GIR amendments, the benchmark, and what comes next.
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.
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.
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.
Senior Director, Head of Tax Europe, APAC & CEE, EPAM Systems
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.
Senior Director, International Tax, Columbia Sportswear
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.
Head of Tax Accounting, NXP Semiconductors
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.
Partner, MJ Associates
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.
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.
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
Qualifying for the CbCR Safe Harbour eliminates unnecessary calculations, while the Safe Harbour assessment and supporting data remain fully documented.
Every Filing Makes the Platform Smarter
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.
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.
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.
Download the Merged Record, the full filing the authority will hold, or the Amendment Record, just the changed sections.
Where does your team stand?
Four questions, measured against the 1,700+ returns filed across 34 jurisdictions this season.
Choose your jurisdictions and current stage to see your position against the season.
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.