A lean global tax team takes on Pillar Two
For this Swiss-parented multinational insurance group, Pillar Two compliance is managed by a lean, globally coordinated tax organization. The U.S. and UK tax teams collaborated on the group’s global Pillar Two implementation from the outset, with the U.S. team leading the overall program and the UK team contributing to the broader global analysis while also taking responsibility for coordinating the European compliance process as well as supporting local implementation across the region. Local advisors provide jurisdiction-specific compliance and technical expertise as needed, especially in Switzerland.
Unlike country-by-country reporting, which was largely informational, Pillar Two data drove actual tax liabilities, which meant the same data collection process the team had run for years suddenly carried far more weight. Moreover, the data collecting process had to be further refined for granular details required for the Global Information Return (GIR).
Data Integrity and Compliance Obstacles
The team’s biggest recurring challenge was one familiar to many multinational tax functions: obtaining the data required for Pillar Two. Entity-level financial information was collected through close collaboration with accounting and finance teams across the jurisdictions in which the group operated, leveraging the company’s established country-by-country reporting process and templates. As the project progressed, the evolving Pillar Two requirements identified additional data elements that extended beyond those historically needed for financial reporting or country-by-country reporting. One example involved several Latin American jurisdictions, where entities that were initially expected to be outside the scope of Pillar Two became subject to the calculations following the implementation of the UK Income Inclusion Rule (IIR) in 2024 through an indirect parent jurisdiction.
The global implementation process also highlighted the importance of comprehensive data validation. Pillar Two calculations are highly sensitive to individual data elements, meaning that relatively minor data inconsistencies such as differences in sign conventions for related-party revenue or tax amounts across source systems could materially affect a jurisdiction’s effective tax rate. Through iterative validation and reconciliation, the team identified and resolved these issues as part of this global implementation process.
That same first-year unpredictability carried into filing of the GIR itself. The company’s first Swiss submission was rejected over a mere apostrophe in one entity’s name, which turned out to be only one of a series of validation errors that surfaced as the team worked through its first-ever GIR filing season.
Selecting Orbitax for Pillar Two Compliance
The company’s tax leadership decision to implement Orbitax and file in-house reflected its long-term outlook as to how it wanted to approach Pillar Two compliance. Although the company already had an established process and software solution for preparing its Country-by-Country Reporting (CbCR) XML file, Pillar Two introduced significantly broader calculation and compliance requirements than CbCR alone. Recognizing that compliance obligations would continue to expand as more jurisdictions implemented the GloBE Rules, management selected Orbitax to provide an integrated platform supporting both the Pillar Two calculations and the associated global compliance process.
Ahead of finalizing 2024 country-by-country data, the team also used Orbitax’s GMT solution as an independent check against its own Excel-based calculations, a step that helped surface and correct data issues before the GIR filing season began in earnest.
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Once those were aligned, I felt pretty good. We knew going into December that we were in a safe harbor position in every jurisdiction we operated in.
International Tax Manager
Swiss-parented multinational insurance group
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Managing the Filing Season and Technical Hurdles
Resolving validation errors was, in the team’s own words, the most demanding part of the season, and that was where the platform and the people behind it worked together. XatBot, the AI copilot built into Orbitax, helped the team work through many of the day-to-day issues that came up during preparation. Where an issue went beyond what the software could resolve on its own, the Orbitax support team stepped in directly, and stayed engaged through resolution rather than treating each ticket as a one-off problem to fix.
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The support staff was great. All the way up the chain. That’s really why we filed on time.
International Tax Manager
Swiss-parented multinational insurance group
”
That partnership extended beyond the company’s own validation work. After the company had cleared its own errors, the Swiss filing was rejected even though the underlying data appeared to be correct. The issue was ultimately traced to the Swiss Federal Tax Administration’s submission process itself. Rather than leaving the client to navigate that alone, Orbitax worked directly with the Swiss tax authorities to resolve it.
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At that point it was really just Orbitax dealing with the Swiss FTA. A couple of things came back that I had to act on, and then we filed, successfully, on June 24th, before the June 30th deadline.
International Tax Manager
Swiss-parented multinational insurance group
”
Alongside the Swiss filing, the team also completed a UK GIR filing through Orbitax’s machine-to-machine transmission capability, working with colleagues in the UK to resolve a couple of data issues along the way. Both filings, Switzerland and the UK, were completed a full week ahead of the June 30 deadline.
FY2024 Compliance Results
The company filed successfully in Switzerland and the UK by June 24, 2026, six days ahead of the FY2024 GIR deadline, having cleared a first-year season of validation errors. The team’s own data checks, cross-validated through Orbitax ahead of filing, gave tax leadership confidence in the company’s safe harbor position across every jurisdiction well before the season’s most demanding weeks began.
Key Takeaway: The Value of End-to-End Compliance
This filing shows what an end-to-end Pillar Two platform means in practice for a lean, centralized tax team managing a global footprint largely through local tax firms. Orbitax carried the return from calculation, through GIR preparation and validation, to accepted electronic transmission in two jurisdictions, without the tax team needing a separate system or process for each jurisdiction with a separate local firm. When issues went beyond what the software or XatBot could resolve on the client side, whether a validation error or a submission issue on a foreign tax authority’s own system, Orbitax’s support team took ownership of it directly, including engaging the Swiss FTA on the company’s behalf. For a first-year filing season with no established playbook, that combination of platform breadth and hands-on support ensured that a demanding and challenging compliance obligation was filed ahead of the deadline, despite all of the extensions being granted to taxpayers in many jurisdictions.
Looking ahead
The team is evaluating Orbitax’s data collection tools to automate the Excel-based data requests and is considering extending its use of Orbitax to country-by-country reporting.
How Orbitax supports Pillar Two GIR filing
The Orbitax International Tax Platform provides end-to-end support for the Pillar Two compliance lifecycle, from calculations and GIR population through XML validation and direct transmission to tax authorities that have embraced machine-to-machine filing technology. Current capabilities include an extensive library of Pillar Two forms across jurisdictions worldwide, machine-to-machine transmission live for Switzerland, the UK, and other jurisdictions, built-in XML schema validation aligned to OECD and jurisdiction-specific requirements, XatBot, the AI copilot built into the platform, and a dedicated premium support offering available.