As multinational groups prepare for the first large-scale Pillar Two filing cycles, many are discovering that the challenge extends far beyond performing OECD model-rule calculations or connecting to a filing endpoint. The real operational burden lies in coordinating global and local-country calculations, GIR preparation, jurisdiction-specific filings, and submission workflows across dozens of tax authorities simultaneously.

In practice, Pillar Two compliance requires organisations to coordinate multiple layers of interdependent calculations, filings, and reporting obligations across jurisdictions that are implementing the rules differently and on different timelines.

This includes:

Global OECD GloBE calculations based on the OECD Model Rules
Separate local-country Pillar Two calculations for jurisdictions exercising taxing rights over constituent entities, based on domestic implementation and interpretation of the rules
Reconciliation between OECD and local-country calculations, including safe harbour adjustments, transitional provisions, and jurisdiction-specific variations
Preparation of the GloBE Information Return(s) (GIR), together with additional local-country filings, notifications, and QDMTT returns
Jurisdiction-specific filing workflows, validations, and submission processes across multiple tax authorities simultaneously

Similarly, local-country QDMTT filings depend on jurisdiction-specific calculation outputs, which may diverge materially from OECD model-rule calculations as countries continue introducing domestic variations.

As filing obligations expand globally, tax teams are increasingly facing the prospect of managing:

multiple calculation frameworks,
overlapping filing obligations,
evolving local-country requirements,
and fragmented submission processes

all within compressed filing timelines.

For 2024 alone, the approximately 40 jurisdictions implementing Pillar Two are expected to introduce an estimated 150 Pillar Two-related forms, filings, notifications, and reporting obligations across global and local compliance frameworks.

This rapidly expanding filing landscape is increasing pressure on tax teams to move from fragmented compliance processes toward scalable operational models.

Against this backdrop, Orbitax today announced that Orbitax Global Minimum Tax (OGMT) is an officially recognized solution for local Pillar Two filings in the United Kingdom and is ready to support direct transmission of filings to the Canada Revenue Agency. In the Netherlands, where the Pillar Two filing portal is scheduled to open on June 1, Orbitax is working closely with the Dutch Tax Authorities to support filing readiness. Submission credentials for all other jurisdictions supporting machine-to-machine filings are expected to follow shortly.

These credentials enable Orbitax to support direct submission of Pillar Two filings to tax authorities, complementing its broader Orbitax Global Minimum Tax (OGMT) platform.

Why filing connectivity alone is not enough

Machine-to-machine filing connectivity is an important capability, but it represents only the final stage of the compliance lifecycle.

The larger challenge for multinational groups is establishing a scalable and controlled process capable of managing:

data consistency across jurisdictions,
calculation dependencies,
governance and review workflows,
filing readiness,
and ongoing regulatory change.

Many approaches in the market continue to rely on OECD-based calculation engines supplemented by manual local-country adjustments, disconnected templates, and separate filing processes.

As a result, tax teams are often required to manage calculation dependencies, reconcile local-country variations manually, and coordinate multiple workflows outside the platform before filings can be prepared and submitted.

As local-country QDMTT rules continue to evolve, and as GIR requirements mature across jurisdictions, these operational dependencies become increasingly important.

Orbitax’s approach: integrated end-to-end compliance

The Orbitax Global Minimum Tax (OGMT) platform was designed specifically to address the operational realities of multinational Pillar Two compliance.

Rather than treating:

calculations,
GIR preparation,
local-country filings,
and transmission

as separate activities, OGMT provides an integrated end-to-end workflow that supports:

OECD and local-country-specific Pillar Two calculations
Automated sequencing and dependency management
GIR and local-country filing preparation
Data consistency across reporting obligations
Workflow governance and auditability
Direct machine-to-machine submission to tax authorities

This enables organisations to move from fragmented and highly manual processes toward a scalable Pillar Two compliance operating model.

Preparing for the next phase of Pillar Two

Pillar Two compliance is increasingly shifting from a calculation exercise to an operational execution challenge.

As jurisdictions continue introducing domestic variations to the OECD framework, maintaining consistency between global and local-country compliance processes is becoming increasingly complex.

The ability to:

coordinate global and local-country calculations,
manage filing dependencies,
support GIR preparation,
and execute filings consistently across jurisdictions

will become a key determinant of filing readiness over the coming cycles.

For additional insight into the Pillar Two filing landscape and the different filing obligations emerging across jurisdictions, see: The Pillar Two Filing Landscape: Understanding Form Types and How to Stay on Top of Them

Explore how Orbitax supports scalable end-to-end Pillar Two compliance across calculations, GIR preparation, local-country filings, and transmission workflows. Book a meeting today.