Own your Pillar Two positions.
Your annual reports go in. A validated GIR comes out. In between, every figure is verified against your own documents, every judgment is yours to make — informed by reviewed case law from 58 jurisdictions — and every line of the calculation carries its OECD article.
The AI reads. It never counts.
Three independent readings. One human sign-off. Every number can defend itself.
A filing that is statutory, annual — and unforgiving.
Groups with €750M+ in revenue must now compute an effective tax rate for every jurisdiction they touch. Below 15%, a top-up tax is triggered. The GloBE Information Return is filed annually, for as long as the group exists, under rules already in force in 55+ jurisdictions — and errors carry penalties.
The first cycle is behind everyone now. Most groups survived it the same way: internal spreadsheets, advisory hours, grey zones nobody wanted to own, and nothing reusable for next year. The positions taken in a hurry in year one are quietly becoming precedent for every year that follows.
The moment to go from surviving the filing to owning your positions is between cycles — not in March, when the deadline is driving.
The grunt work systematised. The judgment kept.
- 01Readevery figure extracted by three genuinely different techniques — disagreement is the signal
- 02Reviewa human signs off on every document — approval stays locked while flags remain
- 03Calculatedeterministic engine, per jurisdiction — same inputs, same filing, every time
- 04Take a positionevery judgment call three ways, recomputed for real — and intra-group flows lit up with both countries’ reviewed transfer-pricing rules
- 05FileGIR-XML validated against OECD’s official schema — with the audit trail built in
Three seats at the table. One page for each.
The work itself
Three-way verified extraction, locked sign-off, a deterministic engine, and calibration with statute and case law behind every grey zone. The judgment stays with you — better armed.
For tax & legal teams →The line item that never closes
GIR recurs every year, forever. What you bought last cycle was hours; what you own after this one is positions — reusable, defensible, and priced in top-up terms per decision.
For the CFO →The two questions you always ask
Can we trust the knowledge, and what happens if the supplier disappears? Both answered by design — adversarial review, escrow per contract, and data that never leaves your machine.
For procurement →Independent tax practice? There is a licence built for you — for advisory firms →
Built by Hallengren’s — one hand, one responsibility.
Pillar Two is built end to end by Henrik Hallengren — a systems builder for regulated environments, not a software giant and not a firm. That is a feature for this category: one contact surface, one person who can show you every link in the chain, and a system designed so that nothing in it has to be taken on faith. Currently in dialogue with groups in pharma, banking and industrials.
“Systems where the answer must be right, traceable and defensible in front of a regulator.”