The operational phase of Pillar 2 marks a turning point for multinational groups subject to the global minimum tax.
After regulatory analysis comes execution.
Organisations must now produce, secure and submit a GloBE Information Return (GIR) – referred to in France as the Déclaration d’Information GloBE (DIG) – in full compliance with OECD requirements.
A more demanding reporting framework than expected
Initial attention focused on calculating the Effective Tax Rate (ETR), QDMTT or the Income Inclusion Rule (IIR).
However, operational reality goes much further.
Producing a GloBE return in XML format requires highly structured data. Organisations must comply with the OECD’s XSD schema and integrate local tax authority requirements.
Each jurisdiction may introduce specific controls.
In France, for example, the tax administration has added several validation checks. These include:
- the format of entity Tax Identification Numbers (TINs),
- file naming conventions,
- compression formats,
- consistency checks across reported figures.
In addition, the French tax authorities already maintain a list of entities expected to file a GloBE return, based on prior corporate tax disclosures.
Audit trail: a critical requirement
In the event of a tax audit (which may occur several years after filing), the audit trail becomes essential.
Each data point must be traceable. Each change must be documented. Each calculation must be justified.
Organisations must also be able to submit corrected filings when necessary.
Pillar 2 rules explicitly allow for amended returns, but under strict conditions.
XML format: a major technical challenge
The XML format represents a key complexity.
It is designed for machine-to-machine communication, making manual reading or correction extremely difficult without dedicated tools.
The GloBE return must follow a precise structure. This structure depends on specific elections, including transitional safe harbour rules based on Country-by-Country Reporting (CbCR).
Moreover, analysing the XML schema helps clarify certain GloBE rules that remain complex in practice.
For instance, rules involving data transfers between entities require TIN identifiers at two levels:
- the reporting entity,
- the counterparty entity.
This applies in particular to:
- transparent entities,
- permanent establishments,
- investment entities,
- controlled foreign companies.
For organisations relying on spreadsheets or partially adapted tools, transitioning to XML represents a significant technical challenge.
In many cases, XML becomes a revealer of tax system maturity.
Successful validation with the French tax authorities
In this demanding context, kShuttle successfully validated the production of the GloBE Information Return (DIG) in XML format with the French tax authorities.
This milestone confirms both the technical compliance and robustness of the platform.
The solution covers all GloBE requirements, including:
- data collection and structuring,
- safe harbour testing,
- ETR calculations by jurisdiction and category,
- option management,
- QDMTT and IIR calculations,
- production and storage of returns,
- management of amended filings.
Delivered as a SaaS solution within a dedicated environment hosted in France, the platform enables real-time calculations, simulations and full data traceability.
ExRP®: an integrated approach to regulatory requirements
The Pillar 2 solution is part of kShuttle’s Extended Regulatory Platform (ExRP®).
This platform unifies financial, tax and ESG reporting within a single interface.
In an environment shaped by multiple regulations (CSRD, EU Taxonomy, GHG, IFRS 16), data convergence becomes critical.
It strengthens both control and efficiency across processes.
A structural challenge for information systems
Pillar 2 is not just a tax reform. It drives a long-term transformation of processes and information systems across multinational groups.
Today, the ability to produce a compliant XML GloBE return is becoming a key indicator of maturity.It directly impacts the security and reliability of tax reporting frameworks.
