OECD Pillar Two Top-Up Tax Exposure
Quantify expected top-up tax by comparing jurisdictional effective rates with the Pillar Two minimum after payroll and tangible asset carve-outs.
General information only — confirm Pillar Two computations with your tax advisors.
Examples
- $120,000,000 profit, $12,000,000 taxes, 15% minimum, 5% carve-out ⇒ Top-up tax $5,700,000.00 on $114,000,000 GloBE income.
- €45,000,000 profit, €9,900,000 taxes, 15% minimum, 5% carve-out ⇒ No top-up; effective rate sits 7.00% above minimum.
FAQ
How is the effective tax rate calculated?
The calculator divides covered taxes by jurisdictional profit before applying carve-outs, mirroring the GloBE effective tax rate definition.
What happens if my carve-out removes all profit?
When the carve-out equals or exceeds total profit the jurisdiction has no GloBE income to test, so the tool reports zero top-up tax.
Can I model safe harbour transition rules?
Safe harbours require additional metrics not captured here; use this output as a baseline before layering transition relief calculations.
How do qualified domestic minimum top-up taxes (QDMTTs) factor in?
If a QDMTT applies, enter the post-QDMTT effective rate in the covered taxes field; the calculator will then highlight whether residual IIR/UTPR exposure remains.
Additional Information
- Inputs accept any currency; results display using USD-style formatting for readability.
- Substance carve-out reflects the payroll plus tangible asset exclusion expressed as a percentage of profit.
- Covered taxes should include current tax expense net of refundable credits, aligned with GloBE guidance.
- If no minimum rate is provided the model defaults to the standard 15% global minimum.