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Pillar 2 in practice.

Notes on the operational side of Pillar 2: data, tooling, deadlines, process.

16 July 2026 5 min Safe Harbour

CbCR Safe Harbour: three tests, one decision per jurisdiction

How the de minimis, simplified ETR, and routine profits tests work in the Transitional CbCR Safe Harbour - when each one is enough and how to avoid common mistakes.

26 June 2026 4 min GIR

GIR Final Validation: What to Check in the Last Week

Five areas to verify before filing GloBE Information Return - when data is ready but the risk of error is still high.

22 June 2026 4 min GIR

The last 8 days before GIR FY2024: what can still be fixed, and what can't

A management view: which data and process gaps can still be closed before 30 June 2026, and which now just need to be logged as a risk.

12 May 2026 5 min Safe Harbour

Transitional CbCR Safe Harbour: where data quality usually breaks

The three data areas that most often decide whether the simplified TCSH tests actually hold up - and how to close them operationally.

28 April 2026 6 min GIR

Data readiness for the GIR: a source-data checklist

A practical checklist of the data sources to map before you start filling in the GloBE Information Return - organised around data roles and owners.

8 April 2026 4 min GIR

The GloBE deadline calendar: setting project milestones that hold

How to translate Pillar 2 regulatory deadlines into a realistic project schedule with a buffer - a management view, not just a tax one.

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Operational Pillar 2 (GloBE) implementation for multinational groups.

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Disclaimer. This website and the services offered are coordination, project-management and implementation services. They do not constitute tax or legal advice within the meaning of the Polish Tax Advisory Act of 5 July 1996. I do not provide opinions, rulings or interpretations regarding tax obligations. Tax-qualification decisions should be confirmed by a licensed tax advisor, legal counsel or attorney.
© 2026 Paweł Dziadek. All rights reserved. pddoradztwo.pl

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