Pillar Two Readiness &
QDMTT Advisory
A 10-service framework closing critical Big 4 gaps. We model GloBE ETR, test Transitional Safe Harbours, and restructure tax holiday architectures (Section 80LA, 115BAB) to prevent unintended top-up tax.
GloBE ETR & Safe Harbours
Rigorous multi-jurisdictional modelling to identify precise top-up tax exposure. We utilize your CbCR data to relentlessly test and secure Transitional CbCR Safe Harbours (SbS).
Tax Holiday Protection
Analyzing the erosive impact of GloBE on Indian tax holidays (Sections 80LA, 10AA, 115BAB, 80-IA). We engineer Substance-Based Income Exclusions (SBIE) to maintain your post-tax yield.
IAS 12 & QRTC Alignment
Bridging the gap between tax and accounting. We provide comprehensive Financial Statement Advisory (IAS 12) and map disparate financial data for Qualified Domestic Minimum Top-up Tax (QDMTT) reporting.
Core Advisory Deliverables
Pillar Two requires unprecedented coordination between tax, accounting, and IT. Our 10-service framework provides end-to-end readiness, resolving the complex blind spots left by standard Big 4 assessments.
GloBE ETR Modelling
Dynamic projection of your Effective Tax Rate under GloBE rules. We isolate jurisdictions falling below the 15% threshold and quantify the exact top-up tax liability across the group structure.
Transitional Safe Harbour (SbS)
Strategic deployment of Country-by-Country Reporting (CbCR) data to test and secure the De Minimis, Simplified ETR, and Routine Profits transitional safe harbours, delaying complex compliance.
Tax Holiday Interaction
Restructuring operational assets to shield incentives. We evaluate the interaction of Section 115BAB (manufacturing) and Section 10AA (SEZ) against the Income Inclusion Rule (IIR) and UTPR.
GIFT City GloBE Strategy
Protecting the 10-year 100% tax exemption under Section 80LA for IFSC units. We optimize tangible assets and payroll metrics to maximize the Substance-Based Income Exclusion (SBIE) carve-out.
Financial Statement Advisory (IAS 12)
Bridging the accounting mandate. We draft the mandatory qualitative and quantitative disclosures required under IAS 12/Ind AS 12 for financial statements regarding Pillar Two current and deferred tax impacts.
Data & Technology Strategy
Benchmarking Big 4 tax engines and identifying critical data gaps. We map the 150+ data points required across disparate ERP systems to ensure seamless, automated QRTC and GIR generation.
GloBE Impact & Implementation Lifecycle
Pillar Two readiness is a phased, iterative process. We move organisations from initial data diagnostics to full structural optimization and automated compliance reporting.
Safe Harbour & Baseline ETR Modelling
We extract qualified CbCR data to run the three Safe Harbour tests. For jurisdictions failing the tests, we compute the baseline GloBE ETR, isolating the specific entities driving the group’s top-up tax liability.
Tax Holiday Optimisation & Restructuring
We analyze the impact of local tax incentives (e.g., SEZ, manufacturing rates) that drag ETR below 15%. We then restructure asset and payroll distribution to maximize the Substance-Based Income Exclusion (SBIE), shielding profits from top-up tax.
QDMTT Readiness & IAS 12 Alignment
Finalizing the compliance posture. We prepare the group for local Qualified Domestic Minimum Top-up Tax (QDMTT) filings in implementer countries and finalize mandatory IAS 12 disclosures for annual financial statements.
Who Needs Pillar Two Advisory?
Pillar Two fundamentally alters the value of global tax planning. Our practice supports €750M+ revenue threshold MNEs and their localized subsidiaries navigating the new 15% floor.
| Client Profile | Indicative Scale | Strategic Imperative & Solutions |
|---|---|---|
| Indian Outbound MNEs | Consolidated Rev €750M+ | Managing the Income Inclusion Rule (IIR) at the Ultimate Parent Entity (UPE) level, requiring comprehensive modelling of overseas subsidiaries in low-tax jurisdictions (e.g., UAE, Singapore). |
| Inbound Subs of Global MNEs | India operations of global groups | Protecting Indian tax holidays (like 115BAB 15% corporate tax rate) from being neutralized by the parent company’s home jurisdiction under the UTPR or local QDMTT. |
| GIFT City IFSC Entities | IFSC Banking / Fund Units | Navigating the direct conflict between Section 80LA’s 0% tax holiday and the 15% global minimum tax, requiring sophisticated SBIE (payroll/asset) optimisation strategies. |
| Companies with Major Tax Holidays | SEZ Units, Infrastructure (80-IA) | Preventing the erosion of hard-won domestic tax incentives. We compute the exact GloBE ETR drag caused by the holidays and deploy deferred tax (QRTC) adjustments. |
Implementation & Compliance
We do not stop at the advisory memo. Strategix executes the necessary filings and coordinates seamlessly across interconnected tax and regulatory frameworks.
| Service Area | Filings & Cross-Vertical Connections |
|---|---|
| GloBE Information Return (GIR) | Preparing and submitting the standardized GIR, ensuring hundreds of complex data points are accurately mapped to the OECD’s XML schema. |
| Domestic QDMTT Filings | Executing local tax filings in jurisdictions that have enacted a Qualified Domestic Minimum Top-up Tax, ensuring local tax credits are properly credited upstream. |
| Transfer Pricing Alignment | Vertical 13 Synchronizing the Pillar Two safe harbour test data directly with existing Country-by-Country Reporting (CbCR) and Master File documentation. |
| Entity Setup / Restructuring | Vertical 02 Vertical 04 Adjusting inbound FDI and outbound M&A holding structures to eliminate inefficient entities that trigger unwarranted UTPR or IIR top-up tax penalties. |
Every referral begins with a confidential,
no-obligation assessment.
CA firms, law firms and professional services partners — contact Shreyansh Verma directly to discuss referral arrangements, co-advisory engagements, or a specific client mandate.