Orbitax is introducing a new workflow within its International Tax Platform that enables multinational tax teams to simply upload their already filed 2024 CbCR XMLs (or US 1120 XML for US HQ MNEs) and complete their 2024 GIR and other local Pillar Two filings automatically, within a single integrated workflow.
Using a 2024 US Form 1120 XML for US-parented multinationals, or a CbCR XML for non-US multinationals, the integrated workflow removes the manual heavy lifting and back-and-forth coordination among multiple disparate global teams that would otherwise be required to meet an MNE’s Pillar Two global compliance obligations.
How it works
Once the CbCR XML/1120 XML file is uploaded, Orbitax Global Minimum Tax will automatically populate the entity data input template with all the mandatory fields, including entity name, country of residence, entity type, ownership structures, etc. An optional data collection workflow can then be launched, sending a pre-filled entity data input template to relevant stakeholders for review and returning completed inputs via email.* The workflow will then create a compliance scenario, load the appropriate OECD and local country calculators, determine the GloBE status of all MNE entities, and automatically identify and filter out entities not in scope for Pillar Two. For example, for the 2024 tax year, if the UPE is in the US, entities resident in the US or in countries that have not yet implemented Pillar Two and directly owned by US entities will generally not be subject to any Pillar Two taxing rights and will not be required to complete even the CbCR Safe Harbor calculations.
CbCR Safe Harbor inputs will be pre-populated directly from the CbCR XML (including from Form 8975 if the file uploaded is the US 1120 XML) and sent via email for stakeholder review.** Jurisdictions that qualify under the CbCR safe harbor test are identified early, allowing the workflow to bypass unnecessary calculations. For those jurisdictions that do not qualify, the workflow will generate additional input templates (GloBE income, covered taxes, additional information) that can be populated via data survey and, once the data is sent back, the workflow will complete the required QDMTT and IIR calculations based on local country Pillar Two rules, and proceed to GIR preparation.
The GIR is initially prepared based on the OECD model rules and is automatically populated using data from the OECD and local country calculations from the steps above. Any additional data inputs needed to complete the GIR can be collected via data survey.
The completed OECD GIR will then be used to populate the local country GIR based on the UPE or designated filing jurisdiction, converted into the required XML schema, and transmitted to the relevant tax authorities based on local country transmission requirements. The workflow will then loop back to complete any additional local country GIRs, essentially following the same process of populating the GIR, converting to the XML schema, and transmitting — all in accordance with the local country requirements.
As the final step, the workflow will move on to completing all local country Pillar Two forms, beginning by navigating to the Filing Manager library, where all required filings by jurisdiction/filing category are displayed based on the MNE footprint. A user can then select a form from the list and follow the workflow steps, which include automatically populating the form from the local country calculator, collecting any additional data inputs via data survey, converting the form to the required filing format, and completing transmission either manually or automatically based on local country filing requirements.
*Note: Where the uploaded file is a CbCR XML rather than a US 1120 XML, ownership structures and entity type will not be captured automatically and will need to be completed via data survey.
**The workflow will map the CbCR XML data to the first ETR group in each jurisdiction.
Why it matters
For many multinational tax teams, 2026 marks the first year of full Pillar Two filing obligations. The pressure to get it right is significant as non-compliance carries significant consequences, including specific penalties under local country Pillar Two rules, general civil and criminal penalties for company officers, and potential violation of an MNE’s publicly stated commitment to meet local tax filing deadlines. In addition most local countries have not in fact implemented the OECD safe harbor from interest and penalties for the initial Pillar Two years, which in any event would only apply where an MNE has taken reasonable steps to comply.
The Global Minimum Tax Compliance Workflow described here populates required data from filed tax returns, completes all required calculations based on local country rules, ensures that all local country forms are prepared in accordance with local country XML schemas, and clears all mandatory errors prior to transmission. All of this is driven from a single, and already in hand, US Tax Return or CbCR XML file upload. For tax teams under pressure to meet GIR and local Pillar Two deadlines across multiple jurisdictions, that is a meaningful shift.
Note: MNEs that have already completed both OECD and local country Pillar Two calculations can look at licensing the GMT Filing Manager, where the steps described above are essentially the same except that the OECD and local country calculators will not be engaged by the workflow to complete any of the GloBE calculations (CbCR safe harbor/QDMTT/IIR), moving instead directly to populating the GIR, where users can directly input their relevant amounts from their completed Pillar Two calculation.
See it in action
Explore the workflow through our interactive demos:
To see how Orbitax can take your team from source data to submission-ready filings, register for our upcoming webinar “Pillar Two Compliance Accelerator using 1120 or CBC XML” — where we will walk through the full workflow live, from entity data population through to local GIR filing.