Pillar 2

The GloBE Rules provide for a coordinated system of taxation that imposes a top-up tax on profits arising in a jurisdiction whenever the effective tax rate, determined on a jurisdictional basis, is below the minimum rate. 

To assess and validate the abovementioned, it is required to analyse the stakeholders, systems, data and processes to get to the right set of information.

Sounds complex? 

Let's stop looking at the theoretical approach and start working on data and deliverables!

3- step Approach

1. Research

Execute a Risk & Readiness

  • Analyzing your organisation for safe harbour options.
  • In-depth analysis of data (sources), documentation and stakeholders and determine the gaps

2. Engage

Inform stakeholders on automation initiatives and procedures 

  • Discuss data availability.
  • Discuss company approach.

3. Activate

With research and internal validation complete, it is time to determine the plan of execution and go! 

  • Automation vs. non-automated execution
  • Timeline and monitoring
  • Stakeholder activation
  • Reporting output

How ATC can Help

Base evaluation

Before starting the data discovery and gathering process, it is important to analyze the current process, systems and internal stakeholders. Furthermore, the scope of the applicable entities/ jurisdictions can be analyzed in this pre-process. 

Find and Analyze data

Around 150 - 200 data points need to be sourced per constituent entity. As this data stems from different systems and stakeholders, it can be quite the exercition. Through our solutions/ supported platforms we can assist companies with the data gathering and gap analysis. 


As the information comes from different systems and multiple stakeholders (for whom this all might not sound familiar), it can be challenging to have the right discussions.  We can assist with that. Conducting the conversations with the various departments, discuss the purpose and urgency with the departments and stakeholders. 

As ATC we are an independent party that applies software depending on the best fit for our clients. We have built a pillar 2 data gathering and calculation solution which can be executed on various platforms (a.o. Workiva, TR Onesource and Microsoft Power Suite). Furthermore, we have third party solutions available for the risk & readiness assessment and the eventual filing.

Also looking to actually start instead of talk?