03 · For Corporations & Tax Departments
WHT. Pillar Two. Treaty routing.
Multinational groups run treaty routing on spreadsheets, in Big Four decks, and in Excel + tribal knowledge. We compiled the graph so your in-house team can model, cite, and defend positions without a €200k engagement.
Use cases
Four workflows, one graph.
Withholding Tax Routing
Optimal dividend, interest, and royalty flows on the treaty graph. See which holding structure reduces WHT, with the treaty article cited on every step.
Pillar Two Modeling
GloBE effective tax rate simulation per jurisdiction. QDMTT, IIR, UTPR modeling with legislative source citations.
Transfer Pricing Support
Benchmark treaty-permitted arm's-length ranges. Import your ERP allocation and see edge-by-edge exposure.
Audit-Grade Documentation
Every route ships with a citation trail to primary sources. The engine does not generate case law as free text.
A worked example
DE parent → SG holdco → BR opco
5% WHT vs. 25% headline. €4.2M/yr saved on €30M annual dividend flow. Every citation clickable, every article referenced.
// route.optimize({from: "DE", to: "BR"})
Cited: DTA DE-SG Art. 10 §2 · DTA SG-BR Art. 10 §2 · Effective 2024-01-01
Bring us your hardest case.
60-minute demo. We model a live scenario from your group and hand you the citations.