For many multinational tax teams, the first Pillar Two filing challenge is not calculating top-up tax. It is determining what actually needs to be filed, where, and by whom.
Before the GIR and other returns can be prepared, teams first need to map filing obligations across jurisdictions, identify which entities are in scope, determine where safe harbors apply, and understand which local registrations, notifications, QDMTT returns, and GIR filings are required.
Most organizations are still doing this manually across spreadsheets, entity charts, advisors, and jurisdiction-by-jurisdiction research.
Many tax departments are approaching the June deadline with lean teams, incomplete entity data, and limited time to manually assess filing obligations across dozens of jurisdictions.
Introducing the Pillar Two Compliance Accelerator
Before most tax teams can begin preparing a GIR or local Pillar Two returns, they first need to determine:
- Which entities are in scope
- Which jurisdictions require filings
- Whether transitional safe harbors apply
- Which forms are required in each jurisdiction
- Whether additional registrations or notifications are needed
For many organizations, that work is still being managed manually across spreadsheets, entity charts, advisor emails, and jurisdiction-by-jurisdiction research.
Before the Accelerator
- Export entity data from multiple systems
- Build filing matrices manually in Excel
- Research local GIR and QDMTT filing requirements country-by-country
- Assess safe harbor eligibility separately
- Cross-check ownership structures and filing obligations
- Validate assumptions with advisors before compliance work can begin
With the Pillar Two Compliance Accelerator
- Upload a Form 1120 XML or CbCR XML
- Automatically scope constituent entities
- Automatically apply CbCR safe harbor logic where applicable
- Identify likely GIR, QDMTT, IIR, and registration and notification obligations
- Generate a jurisdiction-by-jurisdiction filing requirement view
- Move directly into filing preparation with a documented starting point
Orbitax designed the free Pillar Two Compliance Accelerator to help multinational tax teams establish their filing footprint before full compliance work begins.
How does it work?
You upload your Form 1120 XML (for US multinationals) or CbCR XML (for non-US multinationals). The platform analyzes your entity structure, determines the GloBE status of constituent entities, applies transitional safe harbor logic where applicable, and filters out entities that are not in scope.
The result is a jurisdiction-by-jurisdiction view of your likely Pillar Two filing obligations, generated from Orbitax’s maintained library of GIR, QDMTT, IIR, registration, and related Pillar Two forms across implementing jurisdictions.
Rather than manually researching filing requirements country-by-country, tax teams receive a structured starting point for compliance based on their own organizational data.
What happens next?
Once the filing footprint is established, teams can decide how they want to operationalize compliance.
Some organizations may only need to prepare a limited number of filings for the current cycle. Others may require a broader workflow covering data collection, calculations, GIR preparation, local country filings, review processes, and XML transmission.
The Accelerator is designed to help organizations move from uncertainty to an actionable compliance plan more quickly.
Important considerations for CbCR XML uploads
The workflow performs best when the uploaded data contains sufficient ownership and entity classification detail.
For US-headquartered multinationals, the Form 1120 XML is typically the preferred starting point because it includes entity structure, ownership, and tax data within a single file.
For non-US multinationals using a CbCR XML, the workflow performs most effectively where:
- there is a single ETR group per jurisdiction
- there are no flow-through entities in the ownership chain
- the entity structure is relatively straightforward
In these cases, the platform can apply safe harbor logic and determine filing obligations with minimal manual intervention.
Because the CbCR XML does not contain ownership or entity type information, organizations using only CbCR data may need to complete a supplemental entity data template to support entity scoping and filing determination.
Where fact patterns involve multiple ETR groups, flow-through entities, or more complex ownership structures, additional manual input may be required, and a broader end-to-end GMT workflow may be more appropriate.
Why it matters for the June deadline
The June 2026 deadline applies to FY2024 GIR filings. For many organizations, this is their first year filing a GIR, and the complexity of that process is only fully visible once you start mapping your obligations against your entity structure. Teams that are still working from a rough sense of their filing footprint are carrying more risk than they realize.
The Compliance Accelerator removes that uncertainty. It gives you a documented, data-driven output you can act on immediately, whether that means purchasing the specific forms you need, briefing your advisory team, or making the case internally for a more complete technology solution ahead of the FY2025 filing cycle.
The workflow is free to run with just a free Orbitax account to access it, which you can create in under two minutes.
From Filing Footprint to Compliance Execution
Once the filing footprint is established, organizations can decide how they want to operationalize Pillar Two compliance based on the complexity of their filing requirements, internal resources, and long-term compliance strategy.
Some tax teams may only need to manage a limited number of filings for the current cycle. In those cases, individual Pillar Two forms can be prepared directly within the platform using Orbitax Filing Manager, which supports bilingual form display, field-level validation, and workflow tracking across teams.
Other organizations may require a broader end-to-end compliance workflow spanning entity scoping, data collection, calculations, GIR preparation, local country filings, and XML transmission. For those teams, the full Orbitax Global Minimum Tax (GMT) solution provides an integrated compliance environment designed to support the ongoing operational demands of Pillar Two.
GMT currently supports machine-to-machine transmission for the UK and Canada, with Germany, Australia and The Netherlands in progress. The platform also includes jurisdiction-specific calculators for QDMTT, IIR, and UTPR requirements and integrates with existing ERP and tax data environments through a broad library of out-of-the-box connectors.
Get started
Upload your 1120 XML or CbCR XML and receive a jurisdiction-by-jurisdiction view of your likely Pillar Two filing obligations. Create a free account to get started today.
If you’d like to talk through your filing situation or learn more about the full GMT solution, our team is available. Contact us here.