Pillar Two Top-Up Tax Excel Sample Calculation

We have prepared a sample (excel) calculation based on our understanding of the Pillar Two Model, also referred to as GloBE Rules. The calculation covers the core flow of the Top-Up Tax Calculation.

Download below the free Pillar Two Sample Calculation:

Global Anti-Base Erosion Model Rules (Pillar Two)

The tax imposed under the GloBE Rules is a “top-up tax” calculated and applied at a jurisdictional level. The GloBE rules use a standardized base and definition of covered taxes to identify those jurisdictions where an MNE is subject to an effective tax rate below 15%. It then imposes a coordinated tax charge that brings the MNE’s effective tax rate on that income up to the minimum rate (after taking into account a substance-based carve-out).

Top-Up Tax Sample Calculation for one single constituent entity (CE)

The calculation includes the:

  • Determination of GloBE Income (or Loss)
  • Adjusted Covered Taxes
  • Calculation of the GloBE Effective Tax Rate
  • Top-Up Tax Rate; and
  • Top-Up Tax Amount

Our sample does not deal with general thresholds, allocations, exclusions, elections, transitional rules, GloBE loss carry forward, Top-Up tax credits, etc. The article numbers refer to the articles of the GloBE Rules.

We will further explain the background and rationale of the various components of our calculation during our Pillar Two Webinar on the 14th of April 2022. Click here to subscribe.

Download the Pillar Two Sample Calculation & Whitepaper: