Pillar Two Data Requirements | GloBE Readiness for EU Groups

Pillar Two: the data requirements for in-scope groupsPillar Two applies a 15% minimum effective tax rate per jurisdiction to groups with consolidated revenue of at least EUR 750 million in two of the four preceding years. The compliance burden is a data problem: GloBE income and covered taxes must be computed per constituent entity, per jurisdiction, from figures that most consolidation systems do not currently hold at that granularity.The EU Minimum Tax Directive (EU) 2022/2523 implements the OECD GloBE rules across member states; the Netherlands implemented them in the Wet minimumbelasting 2024. In-scope groups face an income inclusion rule, an undertaxed profits rule, and — in the Netherlands and many other member states — a qualified domestic minimum top-up tax.The transitional CbCR safe harbours reduce the calculation burden for jurisdictions that pass one of three tests, but only where the CbC report is a 'qualified' one prepared from qualified financial statements. That single condition puts data quality, not tax technical work, on the critical path.What the calculation needs, entity by entity

Financial accounting net income or loss per constituent entity, from the accounts used for the consolidation, before consolidation eliminations

GloBE adjustments: excluded dividends and equity gains, prior-period errors, accrued pension expense, stock-based compensation, arm's-length adjustments

Covered taxes: current tax, movements in deferred tax recast at the 15% minimum rate, uncertain tax positions, and allocations between entities

Substance-based income exclusion inputs: eligible payroll costs and eligible tangible asset carrying values, per entity, per jurisdiction

Ownership structure and entity classification: permanent establishments, joint ventures, investment entities, minority-owned constituent entities

Where existing setups break

Granularity. Consolidation systems often hold data at reporting-unit level, not per legal entity — the level GloBE requires.

Deferred tax. Recasting deferred tax at the minimum rate and tracking the five-year recapture rule needs a deferred tax register per entity that many groups do not maintain.

Payroll and asset data. The substance-based exclusion requires payroll and tangible asset data per jurisdiction, which sits in HR and fixed asset systems rather than in the consolidation.

CbCR quality. If the CbC report is not built from qualified financial statements on a consistent basis, the transitional safe harbour is unavailable and the full calculation applies.

Timing. Top-up tax information returns and local filings run on a longer deadline than the annual report, but the data must be frozen and reproducible from the close.

Sequence the work around the safe harboursThe pragmatic order is: confirm scope; establish a clean constituent entity list; test each jurisdiction against the transitional CbCR safe harbours using qualified data; and build the full GloBE calculation only for the jurisdictions that fail. That keeps the expensive work proportionate — and it makes CbCR data quality the highest-return investment in the programme.Pillar Two readiness checklist

Scope confirmed against the EUR 750m threshold in two of the four preceding years

Constituent entity list complete, including PEs, JVs, and excluded entities, reconciled to the consolidation scope

Jurisdiction mapping per entity, including dual-resident and stateless cases

Entity-level financial accounting net income available pre-elimination from the consolidation source

Chart of accounts tagged for the GloBE adjustment items

Deferred tax register per entity, with recast at 15% and recapture tracking

Eligible payroll data per entity from HR/payroll systems

Eligible tangible asset carrying values per entity from fixed asset registers

CbC report assessed as 'qualified' and built from qualified financial statements

Transitional safe harbour tests run per jurisdiction with results documented

Filing calendar for the GloBE information return and local top-up tax returns

Audit trail and version control on the calculation inputs and outputs

How we would approach this

We treat the constituent entity list as the master dataset — nearly every downstream error traces back to it.

We assess CbCR data quality first, because passing a safe harbour is far cheaper than computing a full ETR.

We build the data extraction into the close so each period produces a reproducible, frozen dataset.

Which groups fall within Pillar Two?Multinational and large domestic groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years, under EU Directive 2022/2523 and, in the Netherlands, the Wet minimumbelasting 2024.What data does a Pillar Two calculation need?GloBE income and covered taxes per constituent entity per jurisdiction, reconciled to the consolidation, plus payroll and tangible asset data for the substance-based income exclusion and the inputs for the transitional CbCR safe harbours.Primary sources

Council Directive (EU) 2022/2523 (Pillar Two) — https://eur-lex.europa.eu/eli/dir/2022/2523/oj

OECD — Pillar Two GloBE rules — https://www.oecd.org/tax/beps/global-anti-base-erosion-model-rules-pillar-two.htm

Wet minimumbelasting 2024 — https://wetten.overheid.nl/BWBR0049432