Pillar Two analysis, in minutes.
A browser-based workspace for designing multinational group structures and analysing IIR · UTPR · QDMTT outcomes in real time. What usually takes days of careful desk-research becomes a few minutes of structured input and visual review.
What it does
Pillar Two analysis traditionally takes hours of ownership-mapping, jurisdictional checks, and rule application — usually scattered across spreadsheets and memos. PillarTwo Architect collapses that work into a single interactive canvas.
- Draw the group. Double-click to add entities, drag to connect ownership. Tidy-tree auto-layout keeps the picture clean.
- Run the engine. Constituent Entity, Joint Venture, MOPE, POPE, IPE — identification and IIR · UTPR · QDMTT mapping across jurisdictions.
- Iterate instantly. Edit any entity, ownership ratio, or charging provision — rerun the analysis and watch the impact ripple through.
- Drill down per entity. Click any entity to highlight its top-up tax flow, payment obligations, and ownership chain — relationships animate in for one-glance clarity.
Core capabilities
Deterministic engine
Direct/indirect ownership closure, circular-ownership handling, and multi-stage CE/JV/MOPE/POPE/IPE/UTPR determination — encoded straight from the GloBE Model Rules, Commentary, and Administrative Guidance.
Real-time iteration
Restructuring, ownership shifts, jurisdiction toggles — change any assumption and the entire analysis updates in seconds. No more reworking spreadsheets.
Per-entity insights
Click an entity to see top-up tax flow, payment obligations, and ownership chain tailored to that specific entity. Animated highlights make complex relationships obvious.
Continuous management
Save the analysis as a .p2a file — optionally AES-256 encrypted — and reload to track structures by fiscal year and structural-change milestone.
Trilingual
Korean · English · Japanese with OECD model rules and jurisdictional terminology preserved across all languages.
Local-only by design
Entity data, ownership ratios, and accounting figures never leave the browser. .p2a files stay on your machine.
Who uses it
- In-house tax teams modelling Pillar Two impact across MNE structures
- Tax advisors running rapid scenario comparisons for client groups
- Researchers and academics studying Pillar Two implementation patterns
- Practitioners and students learning the GloBE rules through hands-on structure design
Built by a Pillar Two expert
The engine codifies the GloBE Model Rules, the OECD Commentary, and Administrative Guidance — together with each adopting jurisdiction's domestic implementation — into a deterministic analysis pipeline. The goal: keep the rigour of professional review while removing the spreadsheet overhead.
Results are reference outputs based on user inputs and the encoded ruleset. Always have a seasoned Pillar Two specialist review the output before applying it in practice.
Get started in five steps
No installation, no account, no sign-up. Open the canvas and you're already running.
- Open the Architect. The canvas appears with a tutorial entity already in view, so the first click is meaningful.
- Load a sample, or build from scratch. Click Load Sample Architecture for a worked example, or double-click empty canvas to add your first entity and drag the blue handles to connect ownership.
- Set each jurisdiction's charging provisions. Mark which Pillar Two rules apply per country — IIR, UTPR, QDMTT (with QDMTT Safe Harbour where relevant). The engine respects each jurisdiction's adoption status when assigning obligations.
- Click Analyze. The engine identifies CE · JV · MOPE · POPE · IPE roles, determines subgroups, assigns paying entities for IIR · UTPR · QDMTT, and allocates top-up tax. Click any entity to open its tailored insight panel.
- Save and continue later. Download your work as a
.p2afile — optionally AES-256 password-encrypted — and reload it to track architectures by fiscal year and structural-change milestone.