Pillar Two simulator · MNE group structure designer · IIR · UTPR · QDMTT visualizer
A browser-based workspace for designing multinational enterprise group structures and analysing Pillar Two (Global Minimum Tax) outcomes — Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT) obligations — in real time. Pillar Two analysis traditionally takes hours of careful ownership-mapping, jurisdictional checks, and rule application; this tool collapses that work into a single interactive canvas.
🌐 Live: pillartwo.app · ⚡ No install · 🔒 100% client-side · 🆓 Free
- What is Pillar Two?
- What this tool does
- Core features
- Who it's for
- Quick start
- Glossary & references
- Background
- Privacy
- Tech stack
- Feedback
Pillar Two is the OECD/G20 BEPS 2.0 Global Minimum Tax — a coordinated international tax regime that requires multinational enterprise (MNE) groups with annual consolidated revenue ≥ EUR 750 million to pay an effective tax rate of at least 15% in every jurisdiction where they operate. Where a jurisdiction's effective tax rate falls short, top-up tax is charged through one of three mechanisms:
| Rule | Korean | Charged by |
|---|---|---|
| IIR — Income Inclusion Rule | 소득산입규칙 | The Ultimate Parent Entity's jurisdiction (or POPE / IPE) |
| UTPR — Undertaxed Profits Rule | 소득산입보완규칙 | Other jurisdictions, allocated by employees & tangible assets |
| QDMTT — Qualified Domestic Minimum Top-up Tax | 적격소재국추가세 | The low-taxed entity's own jurisdiction |
See pillartwo.app/overview for the regime in full, and the glossary for all defined terms.
PillarTwo Architect collapses multi-day Pillar Two analysis into a few minutes of structured input and visual review:
- Draw the group. Double-click to add entities, drag to connect ownership. Tidy-tree auto-layout keeps the picture clean.
- Run the engine. The deterministic analysis engine identifies Constituent Entities (CE), Joint Ventures (JV), MOPEs, POPEs, and IPEs, then maps IIR · UTPR · QDMTT obligations across every jurisdiction in the group.
- Iterate. Edit any entity, ownership ratio, or jurisdictional charging provision — rerun the analysis and watch the impact ripple through instantly.
- Drill down. Click any entity to highlight its top-up tax flow, payment obligations, and ownership chain — relationships animate in for one-glance clarity.
What would otherwise be a multi-day desk-research exercise becomes a few minutes of structured input and visual review.
| Visual structure design | Double-click to add, drag to connect, auto-layout to tidy. |
| Deterministic analysis engine | Direct/indirect ownership closure, circular-ownership handling, multi-stage CE / JV / MOPE / POPE / IPE / UTPR determination. |
| Real-time iteration | Modify ownership, jurisdiction, or rule setting — results refresh instantly. |
| Per-entity insights | Click an entity to see its top-up tax flow, payment obligations, and ownership chain. |
| Trilingual UI | Korean · English · Japanese — OECD model rules terminology preserved across all three. |
| Encrypted save | AES-GCM 256-bit password-protected .p2a files. |
| Continuous management | Save and reload .p2a to track architectures across fiscal years and structural-change milestones. |
| Local-only by design | .p2a files stay on your machine. Entity data, ownership ratios, and accounting figures never leave the browser. |
- In-house tax teams modelling Pillar Two impact across MNE structures
- Tax advisors at accounting firms running scenario comparisons for client groups
- Researchers and academics studying Pillar Two implementation
- Practitioners and students learning the GloBE rules through hands-on structure design
- Visit pillartwo.app
- Try the built-in tutorial, or click Load Sample Architecture for a worked MNE example
- Add entities, connect ownership, set charging provisions per jurisdiction
- Click Analyze to compute CE / JV / MOPE / POPE / IPE / UTPR roles and the resulting top-up tax obligations
- Save your work as a
.p2afile (optionally AES-256 password-encrypted) for later reload
No installation. No account. No sign-up. Free.
- In-app glossary: pillartwo.app/glossary — 27 GloBE terms (IIR, UTPR, QDMTT, MOPE, POPE, IPE, JV, CE, ETR, SBIE, Safe Harbour, blending, CbCR, excluded entity, and more) in three languages
- OECD primary sources: GloBE Model Rules, Commentary, Administrative Guidance
- About the tool: pillartwo.app/about
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 aim is analytical depth that matches and exceeds expert review, without the spreadsheet overhead.
Results are reference outputs based on user inputs and the encoded ruleset. Always have a qualified Pillar Two specialist review the output before applying it in practice.
The service does not collect or transmit analysis data. Entity information, ownership ratios, accounting data, and analysis results are processed entirely client-side. Only the contact form (Formspree) and standard third-party assets (jsDelivr CDN, flag CDN) generate any outbound network traffic; opt-in usage analytics (Google Analytics, Microsoft Clarity) are gated by Consent Mode v2 and remain off until the user agrees.
See the in-app Privacy Policy for the full data-handling notice.
- Static single-page app on Cloudflare Pages
- Vanilla JavaScript / DOM — no framework, no build pipeline beyond esbuild minification
- Leaflet for the in-canvas world map; D3-geo + world-atlas TopoJSON for the orthographic minimap
- Web Crypto API AES-GCM 256-bit encryption for
.p2afiles - Sentry error monitoring (errors-only, no PII)
- Three-language i18n via custom
t()function — 514+ keys across ko/en/ja
In-app contact form: click Contact in the lower-right of the map widget. Issues and pull requests on this repository are also welcome.
If PillarTwo Architect saves you time, please ⭐ star the repository — it helps surface the project to other tax practitioners.
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