// IMMO.QUICK · GATEGLOBE · OECD PILLAR TWO · IIR · UTPR · QDMTT

15 percent, before the dividend moves.

gateGloBE forensically seals that a distribution passes four clusters, structure modelling, jurisdictional ETR calculation, top-up tax exposure, and approval review, before the global minimum tax could be undercut. Support for multinational groups, never a replacement for a tax authority's own recognition.

Request Access → See the architecture

In one sentence: gateGloBE calculates the jurisdictional effective tax rate before every distribution and blocks if an undocumented, unaccounted-for top-up tax would arise.

✓ RELEVANT IF...

You are a multinational group falling under the OECD Pillar Two revenue threshold (€750m)
You need to approve distributions to the parent without undercutting the 15 percent threshold

✕ NOT RELEVANT IF...

You expect a tax authority to automatically recognise the result as a tax assessment
No group above the Pillar Two revenue threshold is involved

// The problem

A distribution can trigger a tax liability that only becomes visible months later.

If a jurisdiction's effective tax rate falls below 15 percent, a top-up tax arises under the IIR or UTPR. gateGloBE models the group structure and calculates the ETR per jurisdiction before a distribution to the holding company is approved.

// Architecture

4 clusters, checked sequentially.

Every cluster is dispositive (material_block_mode: true), a hit blocks bindingly, not merely for documentation.

CLUSTER 1

Structure Modelling

Deterministically models the group structure (parent, holdco, subco, opco per jurisdiction) with the relevant ownership chains.

entity_structure_mapped · jurisdictions_count

CLUSTER 2

Jurisdictional ETR Calculation

Calculates the effective tax rate per jurisdiction under the GloBE adjustment rules and compares it against the 15 percent minimum threshold.

jurisdictional_etr_pct · minimum_rate_threshold

CLUSTER 3

Top-Up Tax Exposure

Calculates the IIR and UTPR top-up tax for every jurisdiction below 15 percent and credits a recognised QDMTT payment against it.

topup_tax_exposure_usd · qdmtt_credit_applied

CLUSTER 4

Distribution Approval

Blocks a distribution as long as a calculated top-up tax is neither reserved for nor documented in the group's tax planning.

topup_tax_reserved · distribution_approved

// Test results

Two tested scenarios.

All values on this page are fictional test data and serve only to illustrate the gate logic.

Scenario	C1	C2	C3	C4	Verdict	Latency
Group with global ETR 17.8%, top-up exposure 0, distribution approved	PASS	PASS	PASS	PASS	GLOBE_SEALED	512ms
SubCo in low-tax jurisdiction, ETR 8.2%, no QDMTT payment documented	PASS	FAIL	not evaluated	not evaluated	BLOCK_GB2_ETR_BELOW_MINIMUM	487ms

// Clarification

What gateGloBE is not.

Not automatic recognition by a national tax authority. The gate delivers a cryptographic proof, not a tax assessment.
Not a replacement for the Pillar Two tax return itself. The gate seals the pre-distribution check, it does not file a return.

15 percent, before the dividend moves.

A distribution can trigger a tax liability that only becomes visible months later.

4 clusters, checked sequentially.

Two tested scenarios.

What gateGloBE is not.

For multinational groups that want to make distributions provable under Pillar Two.