Solutions/GMT24

GMT24

Global minimum tax intelligence for the Pillar Two era.

An enterprise platform for OECD Pillar Two: financial, CbCR, entity, transfer pricing and incentive data converted into a controlled GloBE data model, with versioned rules driving every calculation.

Financial-district skyline at dusk
At a glance
DomainOECD Pillar Two / GloBE
EngineDeterministic, integer arithmetic
RulesEffective-dated OECD + local packs
ModesIn-house group / advisor portfolio
Jurisdiction packscoverage to be confirmed
Source dataAI mappingRulesCalculationExplanationGIRAudit

The problem

Pillar Two is a data problem before it is a tax problem

GloBE calculations need entity-level data that most groups have never assembled in one place: consolidation figures, local tax numbers, deferred tax, incentives, ownership and CbCR — reconciled, at the right level, for every jurisdiction.

A spreadsheet can compute an ETR. It cannot prove, two years later and to an auditor, which rule version and which source figure produced it. GMT24 is built for that second problem.

Who it is for

Group tax directors

Owning the Pillar Two position, the provision impact and the filing.

Local tax and finance teams

Supplying and validating jurisdictional data without owning group logic.

Advisory firms

Running multiple client groups in portfolio mode on one engine.

CFOs and audit committees

Needing a defensible number and a clear view of exposure by jurisdiction.

Core capabilities

01

GloBE scope assessment

Group and entity scoping, revenue thresholds, excluded entities and ownership structure resolved from source data.

02

GloBE income and covered taxes

Financial accounting starting points adjusted through the prescribed items, with deferred tax handled explicitly.

03

Jurisdictional ETR

Effective tax rate per jurisdiction, per year, traceable from the rate back to the individual ledger figures.

04

Safe harbour testing

Transitional CbCR and other safe harbours tested first, so effort goes only where a full calculation is required.

05

Substance-based income exclusion

Payroll and tangible asset carve-outs computed per entity with the transitional rates applied by year.

06

QDMTT, IIR and UTPR allocation

Top-up tax determined and allocated through the charging order, with the ownership chain modelled explicitly.

07

GloBE Information Return support

GIR data points assembled from the same model that produced the numbers, with notification tracking.

08

Scenario modelling and audit trails

Restructuring, incentive and rate scenarios run side by side; every version retained and comparable.

AI handles messy data, mapping, interpretation and explanation. A deterministic engine performs the calculation.

A language model never computes a Pillar Two number. Every figure is reproducible, rule-versioned and traceable to its source.

How the platform works

Five layers, one traceable line from source data to filing

01

Data engine

Ingest, classify and map source data to the GloBE model.

02

Rules engine

Effective-dated OECD and local rule packs, versioned.

03

Calculation engine

Deterministic dependency graph; reproducible arithmetic.

04

Compliance engine

GIR, filings, notifications and deadline control.

05

AI intelligence layer

Mapping, gap detection, explanation and review support.

Example workflow

A first Pillar Two year for a multinational group

Illustrative sequence, not a client engagement.

01

Consolidation, CbCR and entity data are loaded; AI proposes the mapping and flags what is missing.

02

Scope is resolved: in-scope entities, excluded entities and the ownership chain.

03

Transitional CbCR safe harbour is tested; jurisdictions that pass are set aside with the evidence recorded.

04

For the rest, GloBE income, covered taxes, SBIE and jurisdictional ETR are calculated.

05

Top-up tax is determined and allocated through QDMTT, IIR and UTPR in the correct order.

06

Any figure can be opened to its source: rule version, input value, and the document it came from.

07

The GIR data set is assembled and the provision impact reported to finance.

Outcomes

One controlled data model

The provision, the filing and the board number come from the same place.

Effort where it matters

Safe harbours tested first, so full calculations run only where required.

Reproducible numbers

Rule-versioned calculations that can be restated exactly, years later.

Decisions before deadlines

Scenario modelling turns compliance data into planning information.

Implementation timelines and effort comparisons to be added once measured with client data

Data security and auditability

Entity-level access control; local teams see only their jurisdiction.

One-click audit trail from any calculated amount to its inputs and rule version.

Immutable version history for every submission and restatement.

Segregation of preparation, review and approval across group and local roles.

Certifications and independent assurance to be confirmed

Integration

Consolidation and ERP systems for financial and deferred tax data.

CbCR and tax reporting packs, plus entity master data.

Provision tooling, with results returned for the accounting close.

Shared entity and financial data with TP24, and corporate records with LAW24, where those platforms are in use.

Named system connectors to be confirmed

Take your Pillar Two position out of the spreadsheet.

We will run a scoped assessment on your group structure and show the calculation, the safe harbour tests and the audit trail behind every number.

Request a Demonstration