Cat-6 · T627 · Treasury, Strategy & Revenue
v1.0

Pillar Two Side-by-Side Scope Classifier

Declare a group fact pattern and a jurisdiction fact pattern, and get back a condition-by-condition classification against the Qualified SbS Regime and Qualified UPE Regime tests in the OECD Side-by-Side Package. Every verdict names the condition that governs it. Any condition you have not declared is reported as undeclared and raises a manual review flag, never a default answer.

Group structure and jurisdiction-level tax facts are exactly the data a filer will not paste into a hosted service. Everything on this page is computed in your browser. Nothing is transmitted, nothing is stored, and the page makes no network call after it loads.

Source: OECD/G20 Inclusive Framework on BEPS, Tax Challenges Arising from the Digitalisation of the Economy, Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package. Approved and declassified 5 January 2026. Conditions below are drawn from Chapter 5 of that publication. Retrieved from oecd.org on 2026-08-15 and read at that date. That is a dated observation about one retrieval, not a statement about the law as it stands when you read this. Check the publisher for anything later.
Pillar Two SbS Package · OECD Jan 2026 Zero PII Client-Side
Scope & reliance: 🔒 All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only. This page classifies the fact pattern you declare. It does not determine whether any MNE group actually falls inside or outside the scope of anything: that determination needs facts this page does not collect and cannot check. Permitted vocabulary here is classified on declared facts, condition met, condition not met, fact not declared. Deterministic logic · no inference · zero PII · CC BY 4.0.
Why this is a page and not a graph node: a closed-enum classifier is the most node-shaped artifact in this pack, and it was still built as an ordinary page on purpose. An existing sealed node in this estate already applies a headquarters-based exemption inside its allocation. A second hash-bearing node encoding the same regime's scope rule would create two sources of truth for one rule, and the sealed side could not be corrected while proving is paused. A page stays correctable, so this stayed a page.
1 · Rule parameter set (declared, versioned)

These are inputs, not constants baked into the page. The thresholds and dates below are the values read from the retrieved publication on the retrieval date above. The two Central Record lists ship empty on purpose: the publication itself names no jurisdiction anywhere in its 88 pages, and instead provides that a jurisdiction the Inclusive Framework has determined to have a Qualified SbS or UPE Regime is listed as such on the Central Record. Declare the entries you are relying on, and the date you consulted that record. A parameter change is a version bump you make here, never a silent recompute.

2 · Declared group facts

The location of the UPE is what drives both safe harbours. Under the publication the location of the UPE is determined applying Article 10.3, and this page takes that location as a fact you declare rather than deriving it.

3 · Declared facts about the UPE jurisdiction's tax system

Assessment against these criteria is the Inclusive Framework's, not a filer's. Declaring them here classifies your reading of the fact pattern against the published conditions, and is reported as such. Leave anything you do not know undeclared: an undeclared fact is reported as undeclared and raises the manual review flag.