For tax advisory firms & multinational groups
A single working model for intercompany flows, transfer pricing, withholding tax, and Pillar Two Top-up Tax — built for the advisor who needs the numbers right before the client asks the question.
Every cross-border structure now answers to two masters: the transfer pricing rules that governed it for decades, and the GloBE Model Rules that arrived after. This tool holds both at once. Enter a group's entities, intercompany flows, and jurisdictions, and it computes withholding tax leakage, GloBE Income, Adjusted Covered Taxes, the Substance-Based Income Exclusion, and Top-up Tax exposure — jurisdiction by jurisdiction, entity by entity — then drafts a GIR mapped to the OECD's actual filing template, ready to brief a client or a partner.
Cayman, BVI, Bermuda, Jersey, Guernsey, Isle of Man, Luxembourg, Mauritius, and more — headline CIT and withholding rates, participation exemption regimes, and Pillar Two/QDMTT status for each, editable to your own assumptions.
GloBE Income adjustments under Article 3.2, covered tax adjustments under Article 4.1, the Substance-Based Income Exclusion, the de minimis exclusion, Top-up Tax, and the UTPR headcount/tangible-asset allocation key — reconciled end to end.
Mapped to the OECD's July 2023 standard template — MNE Group information, safe harbours and exclusions, ETR and Top-up Tax computation, and attribution — generated from your own data, not typed twice.
Built for advisors modeling exposure ahead of a restructuring, a new jurisdiction, or a Pillar Two filing season — in-house tax directors, boutique advisory firms, and counsel who need a defensible first pass before the full engagement begins.
Pricing
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Not tax or legal advice. A planning aid for directional analysis — every structure still requires a genuine functional/risk analysis and review by qualified counsel in each jurisdiction involved.
