Pillar Two is not a project — it is a permanent, annual obligation in 55+ jurisdictions. Cycle one you bought hours: advisory time, internal spreadsheets, a filing. None of it is reusable. Next year the invoice looks the same, unless what you buy changes.
move the slider — the engine recomputes the top-up for real. Every position argued by three lenses, with the case law attached.
The hours you bought last cycle went to collecting and checking numbers. The system does that part now. The advisory hours you still buy go where they were always supposed to go: judgment on the positions that matter.
Every grey-zone decision shows its amount leverage: move a position from conservative to assertive and the engine recomputes the top-up for real. For the first time, the risk appetite discussion happens in euros per decision — not in an advisor’s memo you can’t interrogate.
Your positions are saved, version-anchored against the knowledge base. When the law moves in a jurisdiction, exactly the affected positions are flagged. Next cycle starts from everything you already decided — with your own answers on record, not a fresh engagement letter.
An advisor who sells a guarantee is structurally forced to the most conservative reading — and you pay the difference in tax, every year. The system shifts that power: your own people choose the group’s risk point, per jurisdiction and per grey zone, informed by three perspectives — the tax counsel, the consultant, the CFO — and the connected case law. Big4 practice stays in the room, as a benchmark on every question.
Everything you show the board, the auditor or an authority carries its OECD article and its documented reasoning. Defensible does not mean guaranteed — it means every number can show where it came from, and every judgment can show who made it and why.
And the sensitive part — which positions you chose — never leaves your machine. Your risk profile is a local file with your team, not a record with a supplier.
Licensed annually per group — a base fee plus a per-jurisdiction rate, so the price scales with your actual footprint. A single-jurisdiction group starts at €47,500 a year; a typical fourteen-jurisdiction group lands around €150,000. Every licence includes independent local counsel review of each jurisdiction’s knowledge base, contractual update SLAs, source and knowledge-base escrow, and unlimited users. Founding member terms are available for the first groups. Or compute your exact number yourself →
No — it shifts them up the value chain, from grunt work to review. Most groups keep their advisors and change what they buy from them.
One afternoon of your tax team’s time. The demo licence is locked to years you have already filed — no live data, and you hold the answer key.
Answered by design rather than size: your positions are already a local file in your hands, and escrow is offered per contract. The full continuity answer, written for your vendor-risk team →