OECD Pillar Two · GloBE · GIR · CbCR · Cert IQ

Pillar Two compliance, 
from screening to filing.

Safe Harbour tests, the full GloBE Articles 3–7 waterfall, and the GloBE Information Return — calculated, governed, and sealed inside your own Microsoft tenant. AI where you want it. None where you don't.

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Art. 3.2 — GloBE Net IncomeArt. 4.1 — Adjusted Covered TaxesArt. 5.1 — Jurisdictional ETRArt. 5.2 — Top-up TaxArt. 5.3 — Substance Carve-outArt. 9.1 — Transition RulesArt. 8.2.1 — Transitional CbCR Safe Harboururn:oecd:ties:globe:v2BEPS Action 13 — CbCRIIR — Income Inclusion RuleUTPR — Undertaxed Profits RuleQDMTT — credited as inputSBIE — 9.4% / 7.4% (FY2026)Minimum rate — 15%
35–50
jurisdictions computed in a single run
Art. 3–7 + 9
the full waterfall — IIR and UTPR included
0
bytes of your data retained outside your tenant, with Cert IQ off
< 60s
to screen every jurisdiction for Safe Harbour
01The problem

Excel got you through year one. It won't survive the filing years.

The first Pillar Two cycles were about estimates. The next ones are about returns, auditors, and defending every number.

Without Cert

  • Spreadsheet models with no record of who changed what, or why
  • Sign-off by email thread — nothing enforces who approved which numbers
  • GIR means re-keying every figure out of Excel into a filing format
  • Transition rates, SBIE phase-downs, and new guidance tracked by hand

With Cert

  • A deterministic engine where every calculation cites its OECD article
  • A server-enforced approval workflow: Draft → Reviewed → Approved → Filed
  • The GIR generated from the same numbers you calculated — no re-keying
  • A sealed Evidence Pack your auditor can rely on, per group, year, and scenario
02The engine

Watch the waterfall do its work.

Eight steps from accounting profit to top-up tax — each one deterministic, each one citing the article it implements. This is the object everything else is built around.

01

GloBE Net Income

Art. 3.2

GNI = PBT + Adj − Excl + QRTC + MTTC

Accounting profit, rebuilt to the GloBE definition — book-to-GloBE adjustments in, excluded income out, qualified refundable and marketable transferable credits counted as income (Art. 3.2.4).

02

Adjusted Covered Taxes

Art. 4.1

ACT = Cur + Def + UTP + Rec − NRTC

Every covered tax that counts, and nothing that doesn't — current, deferred, uncertain positions, recapture.

03

Jurisdictional ETR

Art. 5.1

ETR = ACT ÷ GNI

One rate per jurisdiction. The number the whole regime turns on.

04

Substance Carve-out

Art. 5.3

SBIE = p% × Payroll + t% × Tangible

Real people and real assets earn relief — at rates that step down every year to 2033.

05

Excess Profit

Art. 5.2

EP = MAX(0, GNI − SBIE)

What's left after substance is what can be topped up.

06

Top-up Percentage

Art. 5.2

TUT% = MAX(0, 15% − ETR)

The gap between the jurisdiction's rate and the global minimum.

07

Top-up Tax

Art. 5.2

TUT = EP × TUT%

The exposure, jurisdiction by jurisdiction — with QDMTT paid credited against it.

08

Charging Provisions

Art. 2

IIR → UTPR

Who actually pays: allocated up the ownership chain through the Income Inclusion Rule, backstopped by the UTPR.

15% — the global minimum tax rate

The global minimum. Every number Cert produces exists to get this one right.

04Cert IQ

A second pair of eyes, on demand.

AI where you want it. None where you don't. Every number in Cert comes from the deterministic calculation engine — Cert IQ explains, maps, and reviews. It never computes your figures, and it switches off tenant-wide.

AI account mapping

Point Cert IQ at your trial balance export and it proposes the GloBE account mapping. You approve every line.

GIR pre-filing review

A second pass over your return before it goes anywhere — inconsistencies, gaps, and oddities flagged with reasons.

Ask Cert IQ

A free-text advisor and exposure explainers on every results screen. Ask why a jurisdiction failed a test — get the article-cited answer.

Variance narration

The dashboard explains movements between years and scenarios in plain language, not just deltas.

05Governance

Built for sign-off, not just calculation.

Getting the number is half the job. Cert is built for the other half — review, approval, sealing, and defending it later.

Draft → Reviewed → Approved → Filed, enforced server-side — not by convention
Two-phase sealed filing with controlled amendments
Evidence Pack — a sealed, auditor-ready record per group, year, and scenario
“Why this number?” provenance on every figure, plus full audit trail and data lineage
Filing obligations tracker with GIR deadlines
06Deployment

Runs in your tenant. Deployed in days, not quarters.

Cert ships as a managed solution into the Microsoft environment you already run — we deploy it for you.

A managed Power Platform solution in your existing Microsoft tenant — no new infrastructure, no IT project
Your data at rest stays in your Dataverse environment — nothing is retained outside your tenant
OECD rates and thresholds ship as signed regulatory releases — dated, versioned, ECDSA-signed parameter packs
Multi-scenario what-if, multi-year, CSV and Excel export throughout

See Cert on your own group structure.

A 45-minute live demo with the person who built it. Bring your edge cases.