At first glance, global minimum taxation sounds like a purely tax-related topic. Inpractice, however, Pillar 2 is just as much about data, processes and software. That is exactly why Flick Gocke Schaumburg and Softwarehelden combined their respective strengths: tax expertise on the one hand, and software and platform expertise on the other. Together, we developed the multi-award-winning Pillar 2Management App – built on Cluu.
A 15 percent minimum tax rate. Corporate groups with annual revenues of EUR 750 million or more. Different entities, jurisdictions, accounting data, safeharbour rules and elections. And at the end of it all, the result needs to be a standardized GloBE Information Return.
Anyone who works with Pillar 2 quickly realizes that the challenge is not simply understanding the tax rules. Things become truly complex when data from different systems needs to be consolidated, calculations must remain reproducible, and the entire compliance process has to be repeated reliably year after year.
This is exactly where tax law becomes a software challenge.
And this is where the collaboration between FGS and Softwarehelden began.
When Tax Expertise Meets Software Development
The Pillar 2 Management App brings together two different perspectives.
Flick Gocke Schaumburg contributed its tax expertise, its deep understanding of regulatory requirements and its extensive experience advising companies. We at Softwarehelden contributed our expertise in developing data-driven applications and, with our low-code platform Cluu, the technological foundation.
Our shared goal was not simply to reproduce the complex technical requirements of Pillar 2 in digital form. We wanted to turn them into an end-to-end, transparent and repeatable process.
Because a technically correct calculation alone is not enough.
The right data needs to be available in the right quality and structure, technical rules need to be implemented reliably, and the final results need to be provided in a format that can be reused for reporting and filing purposes.
Pillar 2 Has Arrived in Day-to-Day Operations
With the Minimum Tax Act, Germany implemented the global minimum tax into national law. In principle, the rules apply to financial years beginning after December 30, 2023.
They generally apply to corporate groups whose ultimate parent entity reports annual revenues of at least EUR 750 million in at least two of the four financial years immediately preceding the relevant year. The minimum tax rate is 15 percent.
For many groups with a calendar financial year, June 30, 2026 marked the first major GIR filing deadline. The first minimum tax report is generally subject to a filing period of 18 months following the end of the financial year, with a standard 15-month deadline applying thereafter.
The first filing season also demonstrated that a significant share of the challenges are technical in nature. According to FGS, the creation and transmission of XMLfiles in particular proved to be demanding.
Pillar 2 is therefore a good example of why regulatory processes need bothsubject-matter expertise and technological expertise from the outset.
From Regulatory Requirements to a Digital Process
That is why the Pillar 2 Management App was designed from the beginning as much more than a tax calculator.
Together with FGS, we created a digital process that connects the different stages of Pillar 2 compliance.
The application supports, among other things, the structured collection of tax-relevant data, Transitional Safe Harbours, calculations of GloBE Income and Adjusted Covered Taxes, Substance-based Income Exclusions, as well as the determination of the Effective Tax Rate and Top-up Tax. Elections can also be documented and the relevant information prepared for the GloBE Information Return.
The underlying requirements come from a highly specialized field of tax law. Our role at Softwarehelden is to transform these requirements into an application in which data models, business logic, workflows and the user interface work together in a meaningful way.
That combination is what makes the project particularly exciting for us.
The Real Challenge Lies in the Data
A large part of the technical complexity sits below the visible user interface.
Tax-relevant information may come from ERP systems, consolidation solutions, reporting systems and individual data sources. In addition, there is master data relating to entities and jurisdictions, as well as information that may not previously have been maintained centrally at all.
Building a separate database and application for every new compliance process would quickly create new data silos.
That is why the jointly developed solution is based on Cluu.
Our platform was created to connect existing systems and data sources and make information usable within a shared business context. Cluu's Virtual Database technology makes it possible to establish relationships between data from different sources without creating a completely isolated data environment forevery new use case.
This allowed us, together with FGS, not only to build a Pillar 2 application, but also to create a technological foundation that can support additional tax processes in the future.
Why Adaptability Matters
Regulatory software is never truly “finished.”
Requirements change, data formats evolve and new validation rules are introduced. Pillar 2makes this particularly clear.
In January 2025, the OECD published the XML schema for the GloBE Information Return. Additional guidance for the first filing and exchange cycle followed in June 2026. By September 11, 2026, a revised version of the GIR had already been published.
For us, this illustrates one of the key advantages of a platform-based approach.
When technical requirements change, data structures and applications do not need tobe rebuilt from scratch every time. Rules, data models and workflows can continue to evolve on a shared technological foundation.
The End-to-End Process Makes the Difference
The jointly developed Pillar 2 Management App shows what becomes possible when subject-matter expertise and software expertise work together from the very beginning.
FGS understands the tax requirements and the challenges companies face. We contribute the technical platform and the experience required to translate complex specialist processes into digital applications.
The resultis an end-to-end process: data from different sources is consolidated, validated and processed according to the relevant technical rules. Calculations and decisions remain traceable. The resulting information can then be made available for the GIR and further filing processes.
At the same time, the development process was not focused solely on technical logic.Despite the complexity of the subject matter, the application was also intended to remain understandable and intuitive to use.
Because digitalization only delivers real value when complex expertise is transformedinto a process that people can actually work with.
What We Take Away from the Project
For us at Softwarehelden, the Pillar 2 Management App is a good example of how we approach software development.
The first question is not:
What app should we build?
Instead, we ask:
What data is available? How is it connected from a business perspective? Which processes need to be supported? And how can we create a technological foundation that will continue to work as future requirements evolve?
Together with FGS, we were able to answer these questions for Pillar 2.
The result combines deep tax expertise with our platform technology and our experience indeveloping complex business applications.
Today, the use case is Pillar 2. Tomorrow, reporting requirements may change, additional data sources may need to be integrated, or new tax processes may emerge.
That is exactly what we developed Cluu for.
The Pillar 2 Management App shows what is possible when subject-matter experts and software developers do not work one after the other, but collaborate on a solution from the very beginning: complex requirements, distributed data and numerous individual process steps become one integrated digital process.
