In every market there are hundreds of in-scope groups that are too small for the big firms’ pricing — and every one of them files a GIR this year, and every year after. The firms that serve them need Big4-grade machinery without Big4 overhead. That is the licence.
The engine does the reading, verification and calculation you currently staff or decline. Your hours go where your name matters: review, calibration, sign-off.
GIR compliance recurs every year, for as long as the group is in scope. Year two is this year’s positions, flagged wherever the law moved — not a new project.
The system never signs anything — you do. It hands you the material: three lenses per grey zone, connected case law, and a calculation where every line carries its OECD article.
Firms also act as reviewing counsel: independent local firms sign off a jurisdiction’s grey-zone material and validate new incoming guidance — recurring, remunerated work on pure expertise, engaged jurisdiction by jurisdiction as client footprints bring them into scope. In your own market, that counsel could be you. How each arrangement is structured — scope, remuneration, responsibility — is agreed per firm. Ask us.
Every Pillar Two platform on the market is a calculation engine: rates, effective dates, OECD deviations as parameters. The research databases carry commentary you can read, not positions you can run. The big firms carry both — locked inside their engagements, priced in hours. What none of them sells is reviewed interpretive content wired into the calculation itself, owned by the client. We tested that claim against nine vendors and ten products in July 2026 — it held. That layer is this system’s core, and it is licensable.
What makes it more than a library: every position is calculation input. Move a client’s position within a grey zone and the engine recomputes the top-up for real. When the law moves, the changed cell falls out of reviewed status automatically — and every saved position that relied on it is flagged. Content and machine, one artefact. Three ways to work with it, in the order most firms arrive: the full system under your name — you review, calibrate and sign; the knowledge layer feeding your existing stack — structured data under licence, version-anchored so the audit trail survives every change in law; or reviewing counsel — the remunerated review work described above, which is work we engage you for, not a prerequisite for either licence. Every licence discussion starts with your partners auditing a representative sample of the base, and ends with explicit liability allocation — agreed per firm.