DataTracks Completes First Live GloBE Filing Cycle, Delivering 150+ Pillar Two Returns Across Seven Jurisdictions

Key Facts

• 150+ Pillar Two returns filed in DataTracks' first live GIR filing cycle

• Seven jurisdictions: United Kingdom, Luxembourg, Netherlands, Canada, Cyprus, Czech Republic, Spain

• Filing types: GIRs, domestic top-up tax returns under local QDMTT regimes, UK ORNs, and other jurisdiction-specific filings

• HMRC-recognised for both GIR and UK Tax Return/ORN submissions, one of the providers with this dual recognition, alongside the Big Four

• Direct-to-authority filing where supported; a submission-ready file is generated for manual upload elsewhere

• 20+ years in regulatory reporting; 30,000+ clients across 25+ countries; 450,000+ regulatory reports delivered to date

 “Delivering more than 150 filings across seven jurisdictions in one cycle, involving different deadlines, schemas and domestic top-up tax requirements, is clear evidence our platform holds up under real, first-cycle conditions,” said Saurabh Satija, UK Business Head, BEPS & Pillar Two, DataTracks. “Groups still preparing their first cycle should take one lesson from this: validate before you submit, not after.”

Why This Matters Now

Pillar Two's 15% global minimum tax applies to groups with revenues of €750 million or more in at least two of the four preceding fiscal years. This was the first cycle in which affected groups had to turn that rule into real, jurisdiction-specific filings rather than modelling. The challenge extended beyond calculating the tax: groups had to translate a common global framework into differing local data requirements, validation rules and submission processes.

How the Filings Were Completed

Clients enter data through a structured template that validates as they go, built on the same OECD-reporting platform DataTracks has developed since 2016. DataTracks Oxbow, the company's Pillar Two engine, then checks every line item, converts the data into each jurisdiction's schema, and either files it directly with the relevant tax authority, where supported, or generates a submission-ready file for manual upload. Jurisdiction-specific outputs included XML and JSON submissions in Canada, XML GIR submissions in the Netherlands, and Spain's Modelo 241 Complementary Tax information return, submitted in its prescribed XML-based format.

Because this was the first global GIR filing cycle, regulators were still finalising validation rules in real time. DataTracks pushed updates to its cloud-based platform about once a week through the first month, keeping every client on the latest logic automatically, with zero downtime and no action needed from clients.

That approach also removes a manual step many organisations still face: groups relying on spreadsheets or outside advisers must reconcile each jurisdiction separately, every deadline, with cost and error risk that grow with headcount rather than automation.

“Because validation happens before submission, our clients avoided the rejection-and-refile cycle many organisations faced this season,” said Prakash Ramachandran, Head of Product, BEPS & Pillar Two, DataTracks. “That is the standard we think Pillar Two software should meet as more jurisdictions join the next cycle.”

Client Feedback

Clients pointed to the review mechanism built into DataTracks' Pillar Two product as a particular help during the cycle. One customer said it “provided an easy way to review and double check the data before submitting to the tax authorities.”

What's Next

DataTracks is now preparing clients for the next Pillar Two filing cycle, due in March 2027 for calendar-year groups on a shorter reporting window than the first year. It is also preparing clients for the EU's Public Country-by-Country Reporting rules, which bring a similar jump in complexity and public scrutiny.

Notes to Editors: Key Terms

• BEPS Pillar Two: the OECD/G20 global minimum tax framework designed to ensure large multinational groups with consolidated revenue of €750 million or more in at least two of the four preceding fiscal years are subject to a minimum tax rate of 15%, calculated jurisdiction by jurisdiction.

• GloBE Information Return (GIR): the standardised return submitted by multinational groups that contains their Pillar Two position, generally due 15 months after fiscal year-end (18 months for the first, transitional year).

• QDMTT (Qualified Domestic Minimum Top-up Tax): a domestic top-up tax that meets OECD requirements and allows a jurisdiction to collect tax on profits arising there that are taxed below 15%. Each jurisdiction sets its own return and filing requirements.

• ORN (Overseas Return Notification): a UK-specific HMRC filing confirming where a group's GIR was filed, required when the GIR is filed outside the UK.

• Notifications in other jurisdictions: several jurisdictions in this cycle, including the Netherlands and Luxembourg, require a similar notification confirming where the GIR was filed centrally, under their own local terms.

• HMRC software authorisation: DataTracks appears on HMRC's official list of recognised Pillar 2 software providers, covering both GIR and UK Tax Return/ORN submissions.

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