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Global Minimum Tax Solution

Get ready for Pillar Two: Assess, Connect, Calculate, Comply, and Plan
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Overview

The Orbitax Global Minimum Tax Solution addresses all OECD Pillar Two calculations for provision reporting, GloBE Information Return (GIR) preparation and transmission, and planning, based on local country calculators supported by the tax rules of more than 190 countries.

Calculate your transitional safe harbour exemptions and the global minimum top-up tax, including provisions for the qualified domestic minimum top up tax (QDMTT), the income inclusion rule (IIR), the undertaxed profits rule (UTPR), and the subject to tax rule (STTR) with our Pillar Two calculator.

Our Pillar Two software is cloud based, supports any form of data input, and can integrate with your existing systems using next generation workflow technology to enable collaboration among internal and external stakeholders worldwide.

Pillar 2 Calculations

Automated Workflows Powered by E.A.T.

Tax Rules and Compliance for over 190 Countries

Connections with 90+ ERP & Tax Authority Systems

The two pillars are estimated to levy a total of $275 billion in additional taxes annually on the ten thousand plus MNEs impacted by the rules.

Load Data

The data required for the global minimum tax calculation is organized into six Smart Data input templates. The GMT calculations are based on the data points from these six data input templates.

Data can be loaded through the export and reimport of Excel Data, upload of user defined source files using field mapping, EAT workflows for data collection, or Orbitax Connect- APIs for automated data push and pull with external systems.

Orbitax can consume data in any format. Once the data is in the platform it will be converted into a single proprietary data format that we call QNR and saved on the Orbitax Drive. This makes it possible to combine data points from any source.

Calculate

The Orbitax GMT software has detailed QDMTT, STTR and GloBE (IIR and UTPR) calculations based on each local country’s implementation. The intelligent logic of the Executable Actions Tool manages the sequence and interaction of these local country calculators.

The flexible architecture of the platform allows you to easily update or compare scenarios with changes to the entity footprint or underlying data sets.

Reports & Forms

The Orbitax Global Minimum Tax Solution will support all local country filing requirements (GloBE Information Returns and other local filings) including e-filings where supported.

See a complete report view in Microsoft Power BI. This includes multiple configurable visuals for viewing and presenting results summaries, scenario comparisons, and year-over-year changes.

Share & File

The platform allows you to share or file with local tax authorities, connect to and transmit data to other software solutions, such as ONESOURCE Tax Provision, and provide reports and customized insights to others inside and outside your organization.

Next Gen Workflows with E.A.T.

A built-in workflow tool, the Orbitax Executable Actions Tool (E.A.T.), can automate tasks such as data collection, calculation, report generation, population of compliance forms, and final transmission to tax authorities.

E.A.T. provides total control of workflows customized according to different data needs, with visual review and tracking to easily make refinements as the workflow is deployed.

Glossary of Terms

Abbreviation Description
BEPS 2.0BEPS 2.0 is a global tax reform initiative developed by the OECD to address Base Erosion and Profit Shifting (BEPS) practices that cost countries an estimated 100-240 billion USD in lost revenue annually.

BEPS 2.0 is composed of two parts, Pillar One and Pillar Two.
CbC - Country by Country reportingCountry-by-Country Reporting is a tax transparency initiative developed by the OECD as part of its Base Erosion and Profit Shifting (BEPS) Action Plan
CbCr - Country by Country reportA Country-by-Country Report is a report providing local tax authorities with visibility into revenue, income, tax paid and accrued, employment, capital, retained earnings, tangible assets, and activities. This information is shared with tax administrations in the jurisdictions where the MNE operates, for use in high-level transfer pricing and BEPS risk assessments.
GILTI - Global Intangible Low-Taxed IncomeGILTI is an Income inclusion under Section 951A related to a type of income earned by CFCs and subject to a preferential tax rate through an additional deduction under Section 250.
GIR - GloBE Information ReturnThe GloBE Information Return is a standardized return developed as part of the OECD's Pillar Two initiative. The GIR provides information on the tax calculations made by the multinational enterprise (MNE) group and contains the information a tax administration needs to evaluate the correctness of a Constituent Entity's GloBE tax liability and to perform an appropriate risk assessment.
GloBE - Global Anti-Base ErosionGloBE is a component of the OECD's Pillar Two initiative. The GloBE rules aim to ensure that large multinational enterprises (MNEs) pay a minimum level of tax on the income arising in each jurisdiction where they operate.
GMT - Global Minimum TaxGlobal Minimum Tax establishes a 15% effective tax rate based on the financial accounts of multinational enterprises with annual revenues above €750 million on a jurisdiction-by-jurisdiction basis.
IFRS - International Financial Reporting StandardsIFRS is a set of accounting standards used in over 140 countries worldwide, except for the United States, which govern how financial information should be reported in financial statements.
IIR - Income Inclusion RuleThe IIR is a rule which requires a parent entity to include a share of income from subsidiaries located in a low-tax jurisdiction when calculating a top-up tax under Pillar Two.
MNE - Multinational Enterprise or MNC - Multinational CorporationA MNE is a company that has business operations in at least one country other than its home country. By some definitions, it also generates at least 25% of its revenue outside of its home country.
OECD - Organisation for Economic Co-operation and DevelopmentThe OECD is an international organization of member countries which work together to develop policy standards to promote sustainable economic growth.
OTP - ONESOURCE Tax ProvisionONESOURCE Tax Provision is a web-based software developed by Thomson Reuters to assist with the calculation needs inherent in financial accounting and reporting of income taxes. It is designed to provide comprehensive calculations for federal, state, local, and international jurisdictions, offering scalability and customization to meet the specific requirements of users
Pillar Two (or Pillar 2)Pillar Two is a global minimum tax directive under the OECD that aims to ensure large multinational enterprises (MNEs) pay a minimum level of tax on the income arising in each jurisdiction where they operate.
QDMT - Qualified Domestic Top-up TaxThe QDMTT is a minimum tax included in domestic law to increase domestic tax liability to a minimum rate, as defined by Article 10 of the OECD Pillar Two Model Rules.
STTR - Subject to Tax RuleThe STTR is a treaty-based rule that allows source jurisdictions to impose an additional tax liability on certain intra-group payments in case the recipient is subject to a nominal corporate tax rate below a certain threshold, which is generally 9%.
Subpart FSubpart F is a type of income earned by a CFC, as defined under Section 952. This type of income gives rise to an income inclusion under Section 951.
US GAAP - Generally Accepted Accounting PrinciplesUS GAAP is a set of accounting rules, standards, and procedures used in the United States. GAAP aims to improve the clarity, consistency, and comparability of the communication of financial information.
UTPR - Undertaxed Profits RuleThe UTPR acts as backstop to the IIR which collects necessary top-up tax which was not collected under an IIR.

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