Pillar Two Data Requirements: Collection Checklist by Source

OECD Pillar Two: the data you need to collectPillar Two calculations need, per constituent entity and per jurisdiction: GloBE income based on the financial accounting net income used for consolidation, adjusted covered taxes, substance-based income exclusion inputs (payroll and tangible assets), ownership and entity classification data, and the CbCR figures that drive the transitional safe harbours. Almost all of it exists somewhere in the group; the difficulty is that it is needed at constituent-entity level, on a consolidated accounting basis, on a tax timetable.The EU Minimum Tax Directive implements the OECD GloBE rules for in-scope groups — consolidated revenue of EUR 750 million or more in at least two of the four preceding years. The Netherlands implemented this through the Wet minimumbelasting 2024.The computation is complex, but the failure mode is mundane: the data is not available at the right granularity. Consolidation packages are collected at group-reporting level, not per constituent entity with local tax detail, and the two are rarely reconcilable without manual work.Entity and structure data

Complete list of constituent entities, including permanent establishments, joint ventures and investment entities, with tax residence per entity

Entity classification: ultimate parent, intermediate parent, partially-owned parent, flow-through, excluded entity

Ownership percentages and changes during the year, with dates

Jurisdiction assignment, including tie-breaker outcomes for dual-resident entities

Whether a qualified domestic minimum top-up tax applies in each jurisdiction

GloBE income inputs

Financial accounting net income per constituent entity, on the accounting standard used for consolidation, before consolidation eliminations

Purchase accounting adjustments identified separately, since they are excluded

Excluded dividends and excluded equity gains and losses, per entity

Stock-based compensation, pension expense and policy-disallowed expenses such as fines and bribes

Intragroup transactions not at arm's length, and asymmetric FX gains and losses

Prior-period errors and accounting policy changes affecting the year

Covered taxes inputs

Current tax expense per entity, with taxes excluded from covered taxes stripped out

Deferred tax expense recast at the minimum rate, with the deferred tax reconciliation per entity

Withholding taxes and their allocation to the entity that earned the income

Uncertain tax positions, which are generally excluded until paid

Push-down of taxes for CFC regimes, hybrids and permanent establishments

Post-filing adjustments to prior-year taxes

Substance-based income exclusionThe carve-out reduces top-up tax by a percentage of payroll and tangible asset carrying values, and it is where most groups can materially reduce exposure — if the data supports it.

Eligible payroll costs per entity: employees and independent contractors under group direction, excluding capitalised and international-shipping payroll

Headcount and location, since payroll must sit in the jurisdiction where the work is performed

Carrying value of eligible tangible assets: opening and closing, averaged, excluding assets held for sale or investment

Lease assets: right-of-use asset values that qualify, separated from those that do not

The transition rate applicable to the year, which declines over the phase-in period

Safe harbours and reporting

Transitional CbCR safe harbour: qualified CbCR data plus consolidated-package figures — a qualified financial statements source, not an adjusted one

Simplified ETR, routine profits and de minimis tests per jurisdiction, each with its own data set

The GloBE Information Return, filed within 15 months of year end (18 months for the first year)

Local notification obligations, including the Dutch filing requirements under the Wet minimumbelasting 2024

Retention: the return's underlying data must be reproducible years later, so archive the inputs, not just the output

How to structure collectionThe practical answer is to extend the consolidation package rather than run a parallel tax collection. Add the constituent-entity fields to the existing submission, validate on entry, and reconcile the total back to the consolidated accounts. That gives one dataset serving statutory reporting, transfer pricing and Pillar Two, with one reconciliation instead of three.Pillar Two data collection checklist

Constituent entity register with classification, residence and ownership history

Financial accounting net income per entity, pre-elimination, on the consolidation standard

Adjustment schedule per entity for the standard GloBE income adjustments

Current and deferred tax detail per entity, recast at the minimum rate

Withholding tax allocation and CFC push-down schedule

Eligible payroll per jurisdiction, with capitalised amounts excluded

Eligible tangible asset carrying values, opening and closing, including qualifying leases

Qualified CbCR data reconciled to the consolidation package

Safe harbour tests documented per jurisdiction with the data supporting each

QDMTT applicability assessed per jurisdiction

Collection integrated into the consolidation package rather than a parallel process

Archive of inputs supporting the GIR, retrievable for later review

How we would approach this

We extend the existing consolidation submission with the constituent-entity fields, so there is one source and one reconciliation.

We test the safe harbours on prior-year data first — the cheapest way to find where real exposure sits.

We validate on entry and reconcile to the consolidated accounts, so the tax computation starts from numbers finance already stands behind.

What data should be collected first for Pillar Two?Start with the transitional CbCR safe harbour inputs — qualified CbCR revenue and profit before tax, plus simplified covered taxes — because they determine which jurisdictions require a full GloBE calculation at all.Can the data come from the consolidation system?Partly. Consolidation gives group-level figures, but Pillar Two requires constituent-entity-level GloBE income and covered taxes reconciled back to that consolidation, which usually means extending the reporting package rather than reusing it as-is.Primary sources

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

OECD — Global Anti-Base Erosion (GloBE) Model Rules — https://www.oecd.org/tax/beps/global-anti-base-erosion-model-rules-pillar-two.htm

Wet minimumbelasting 2024 — https://wetten.overheid.nl/BWBR0049452/