The GloBE Pillar Two Global Minimum Tax Model is a 30-module editable Excel workbook designed to help multinational finance, tax, advisory, and review teams analyze the OECD Pillar Two framework in a structured and traceable format. The model uses an illustrative multinational group and is intended to be updated with the user's own entity, jurisdiction, ownership, financial, and tax information.
The workflow begins with a central assumptions module covering the minimum GloBE rate, de minimis thresholds, Substance-Based Income Exclusion transition rates, foreign exchange assumptions, forecast drivers, scenario toggles, and the sequencing of QDMTT, IIR, and UTPR. Separate input modules capture group structure and three years of jurisdictional financial and tax information.
The core calculation engine bridges accounting income to GloBE income or loss, reconciles current and deferred covered taxes, calculates adjusted covered taxes, determines the payroll and tangible-asset based substance exclusion, applies de minimis testing, and calculates jurisdictional effective tax rates, top-up percentages, excess profit, and top-up tax. Transitional CbCR Safe Harbour tests are included, followed by QDMTT, Income Inclusion Rule, and UTPR allocation modules. A dedicated allocation summary reconciles the collection mechanisms and is designed to prevent double counting.
Additional analytical schedules cover deferred tax recast and five-year recapture, permanent and temporary differences, functional-currency translation, FX shocks, implementation and SBIE phase-in, mid-year acquisition or disposal, and legal-entity restructuring. The model also includes a five-year legacy-versus-Pillar-Two cash tax forecast and a diluted EPS and free cash flow impact schedule.
Management outputs include an Executive Dashboard showing group ETR, total top-up tax, jurisdictions below the minimum rate, SBIE benefit, cash tax impact, jurisdictional exposure, allocation mix, and cash tax trends. A Jurisdictional Dashboard provides a selected-jurisdiction profile with current, prior, forecast, threshold, status, source module, and interpretation fields.
The workbook includes a GloBE Information Return working-paper mapping sheet that links selected reporting data points to model source sheets and ranges. It also includes an Audit and Integrity Control with 21 checks and tie-outs, plus a Sources and Version Control sheet documenting the OECD reference basis used in the model.
This model is best suited to multinational tax functions, CFO and finance teams, advisers, consultants, accounting firms, analysts, transaction teams, and internal reviewers that need an Excel-based Pillar Two planning and review tool. It is not an electronic filing engine and does not replace jurisdiction-specific tax or legal advice. The sample entity data should be replaced before use, and current local enactment, qualified-rule status, filing requirements, and administrative guidance should always be confirmed for the relevant period.
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Source: Best Practices in Tax Excel: GloBE Pillar Two Global Minimum Tax Model Excel (XLSX) Spreadsheet, PDMM Financial Models
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