Transitional CbCR safe harbours
Three tests — de minimis, simplified ETR, and routine profit — computed jurisdiction-by-jurisdiction from CbCR data, with deterministic pass/fail logic.
The most rigorous GloBE compliance package a mid-market group can file.
Pillar Two Compliance Engine assembles a documentation-complete GloBE package — every safe-harbour test, every jurisdictional computation, the GloBE Information Return, and local QDMTT/DMTT returns — checked against the OECD Model Rules and Administrative Guidance before a credentialed reviewer releases it.
Every transitional CbCR safe-harbour test150–200 data points per jurisdiction, gate-checkedCbCR · consolidation · trial balance · deferred tax note extractionCredentialed tax reviewer release on every package5-business-day SLA
Why packages fail
A single miscalculation can trigger a penalty or lost safe harbour.
A mid-market multinational's GloBE compliance is only as strong as the data extraction and safe-harbour logic behind it. Miss a covered-tax classification, misapply a transitional safe-harbour test, or fail to reconcile deferred taxes — and the group can lose penalty relief, overpay top-up tax, or face audit exposure.
Most groups run this by hand, from spreadsheets, once a year. The OECD Administrative Guidance has not been read end-to-end since the last update. That is exactly where completeness gaps hide.
Pillar Two Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every file.
1 of 3
transitional safe-harbour tests must all pass to avoid full GloBE computation
The benchmark
Measured against the OECD Model Rules — article by article.
We do not summarize the rules and hope. Every package is scored against a versioned rule pack tied to the exact text of the OECD GloBE Model Rules and Administrative Guidance. These are the provisions each package is held to.
GloBE income determination
Financial-accounting net income adjusted for GloBE exclusions, stock-based compensation, and asset step-ups — extracted from consolidation packs and trial balances.
Covered taxes classification
All income taxes, including deferred taxes and current tax expense, classified per the OECD definition — with judgment chokepoints flagged for reviewer.
Substance-based income exclusion
Eligible payroll and tangible-asset carve-outs computed per jurisdiction, with the 5%/5% transitional rates applied correctly.
GloBE Information Return assembly
General section plus jurisdictional sections for each in-scope country, populated from computed data and reconciled to the CbCR.
QDMTT/DMTT local returns
Qualified Domestic Minimum Top-up Tax and Domestic Minimum Top-up Tax returns drafted per local law templates, with jurisdictional safe-harbour elections documented.
How a package is built
Intake to credentialed reviewer release, with deterministic gates the AI cannot overrule.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A credentialed tax reviewer signs every release. That order is never reversed.
01
Gap Scan
Upload the CbCR, consolidation packs, and trial balances. We return a free completeness read: which safe-harbour tests you already pass, and which data points are missing.
02
Data extraction & reconciliation
As your authorized clerical agent, we extract financial data from CbCR, consolidation packs, and trial balances, reconciling across sources and flagging discrepancies.
03
Grounded computation
Safe-harbour tests, GloBE income, covered taxes, and top-up tax are computed from validated data and the OECD rule pack into field-locked templates — no legal opinions, no invented facts.
04
Deterministic completeness gates
Safe-harbour pass/fail is verified; data points reconcile to source documents; deferred tax notes are cross-checked; any failure blocks release.
05
Credentialed reviewer release
A credentialed international tax reviewer reviews the exception queue and signs the release. Complex covered-tax classifications route to senior reviewer first.
06
Delivery
You receive the package: GIR (general + jurisdictional sections), local QDMTT/DMTT returns, safe-harbour evidence log, reconciliation workpapers, and filing calendar — ready for the tax director to sign and file.
The bar we hold
Rigor you can measure.
100%
Credentialed-reviewer-released
No package ships without a human signature.
5 days
Standard SLA
From complete intake to released package.
<1%
Critical-defect target
Tracked against a gold-standard package library.
4
Data-source types
CbCR · consolidation · trial balance · deferred tax notes, every applicable file.
Why Pillar Two Compliance Engine
Built to be the most thorough option a mid-market group has.
Documentation-complete, by design
The deliverable is completeness itself — every safe-harbour test and data point accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A computation error cannot slip past a rule requirement.
In its lane, on purpose
We prepare documentation and run computations as your clerical agent. We never give legal advice, sign returns, or represent you before tax authorities.
Engagement
Flat fee, per released package. No hourly billing, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any tax savings.
- A free Gap Scan before you commit — see exactly what is missing.
- One flat fee per released GloBE Compliance Package; disclosed pass-through data-extraction costs.
- Optional fixed-fee senior reviewer escalation for complex covered-tax classifications.
- Optional Filing Continuity Add-on for the GIR XML generation and local return e-filing, pre-dated to your filing deadline.
FAQ
Questions, answered precisely.
Is Pillar Two Compliance Engine a law firm?
No. Pillar Two Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Credentialed tax reviewer review is available and recommended for complex classifications.
Do you sign the return or communicate with tax authorities?
Never. Pillar Two Compliance Engine is not a tax preparer and does not sign returns or contact tax authorities. The group's tax director remains the signatory and the party responsible for filing all returns.
What makes a package 'complete'?
Completeness is defined by the OECD rules: all three transitional safe-harbour tests computed, GloBE income and covered taxes determined per Articles 5 and 4, the GIR assembled per Article 10, and local returns drafted per Article 11. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a credentialed-reviewer-released package. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released package, plus disclosed pass-through data-extraction costs. No hourly billing and no percentage of any tax savings or refunds.
See what's missing before it costs you a safe harbour.
Start with a free Gap Scan. Send your CbCR, consolidation packs, and trial balances and we'll return a completeness read against every article of the OECD GloBE Rules.
Documentation-completeness service · not tax advice · the group's tax director files every return.