A lean global tax team takes on Pillar Two

For this Swiss-parented multinational insurance group, Pillar Two compliance is managed by a lean, globally coordinated tax organization. The U.S. and UK tax teams collaborated on the group’s global Pillar Two implementation from the outset. The U.S. team led the overall program and the UK team contributed to the broader global analysis while also taking responsibility for coordinating the European compliance process as well as supporting local implementation across the region. Local advisors provide jurisdiction-specific compliance and technical expertise as needed, especially in Switzerland.

Unlike country-by-country reporting, which was largely informational, Pillar Two data drove actual tax liabilities, which meant the same data collection process the team had run for years suddenly carried far more weight. Moreover, the data collecting process had to be further refined for granular details required for the Global Information Return (GIR).

Data integrity and compliance obstacles

The team's biggest recurring challenge was one familiar with many multinational tax functions — obtaining the data required for Pillar Two. Entity-level financial information was collected through close collaboration with accounting and finance teams across the jurisdictions in which the group operated, leveraging the company's established country-by-country reporting process and templates. As the project progressed, the evolving Pillar Two requirements identified additional data elements that extended beyond those historically needed for financial reporting or country-by-country reporting. One example involved several Latin American jurisdictions, where entities that were initially expected to be outside the scope of Pillar Two became subject to the calculations following the implementation of the UK Income Inclusion Rule (IIR) in 2024 through an indirect parent jurisdiction.

The global implementation process also highlighted the importance of comprehensive data validation. Pillar Two calculations are highly sensitive to individual data elements, meaning that relatively minor data inconsistencies — such as differences in sign conventions for related-party revenue or tax amounts across source systems — could materially affect a jurisdiction's effective tax rate. Through iterative validation and reconciliation, the team identified and resolved these issues as part of this global implementation process.

That same first-year unpredictability carried into the filing of the GIR itself. The company's first Swiss submission was rejected over a mere apostrophe in one entity’s name, which turned out to be only one of a series of validation errors that surfaced as the team worked through its first-ever GIR filing season.

Selecting Orbitax for Pillar Two compliance

The company's tax leadership decision to implement Orbitax and file in-house reflected its long-term outlook as to how it wanted to approach Pillar Two compliance. Although the company already had an established process and software solution for preparing its Country-by-Country Reporting (CbCR) XML file, Pillar Two introduced significantly broader calculation and compliance requirements than CbCR alone. Recognizing that compliance obligations would continue to expand as more jurisdictions implemented the GloBE Rules, management selected Orbitax to provide an integrated platform supporting both the Pillar Two calculations and the associated global compliance process.

Ahead of finalizing 2024 country-by-country data, the team also used Orbitax's GMT solution as an independent check against its own Excel-based calculations, a step that helped surface and correct data issues before the GIR filing season began in earnest.

FY2024 compliance results

The company filed successfully in Switzerland and the UK by June 24, 2026, six days ahead of the FY2024 GIR deadline, having cleared a first-year season of validation errors. The team's own data checks, cross-validated through Orbitax ahead of filing, gave tax leadership confidence in the company's safe harbor position across every jurisdiction well before the season's most demanding weeks began.

Key takeaway: The value of end-to-end compliance

This filing shows what an end-to-end Pillar Two platform means in practice for a lean, centralized tax team managing a global footprint largely through local tax firms. Orbitax carried the return from calculation, through GIR preparation and validation, to accepted electronic transmission in two jurisdictions, without the tax team needing a separate system or process for each jurisdiction with a separate local firm. When issues went beyond what the software or XatBot could resolve on the client side, whether a validation error or a submission issue on a foreign tax authority's own system, Orbitax's support team took ownership of it directly, including engaging the Swiss FTA on the company's behalf. For a first-year filing season with no established playbook, that combination of platform breadth and hands-on support ensured that a demanding and challenging compliance obligation was filed ahead of the deadline, despite all of the extensions being granted to taxpayers in many jurisdictions.

Looking ahead

The team is evaluating Orbitax's data collection tools to automate the Excel-based data requests and is considering extending its use of Orbitax to country-by-country reporting.