Pillar Two Side-by-Side Scope Classifier

Classifies a declared MNE group and jurisdiction fact pattern against the Qualified SbS Regime and Qualified UPE Regime conditions set out in Chapter 5 of the OECD Side-by-Side Package (Inclusive Framework on BEPS, approved and declassified 5 January 2026). Every verdict names the condition that governs it, and any fact the rule needs but the caller did not declare is reported as undeclared and sets manual_review_required rather than being defaulted or inferred. Rule thresholds, effective dates and Central Record listings are declared versioned inputs, never constants embedded in the page: the publication itself names no jurisdiction, and provides instead that qualifying jurisdictions are listed on the Central Record. Classification of the declared fact pattern only. It does not determine whether any group falls inside or outside the scope of anything, and it is not tax advice.

Tool URL: https://ainumbers.co/tools/627-pillar-two-side-by-side-scope-classifier.html AP2/Policy Mandate export: yes