Who does Pillar Two apply to?

Pillar Two applies to MNE groups with annual consolidated revenue €750M+ in at least two of the four preceding fiscal years. In-scope groups may face top-up taxes if any constituent entity has an ETR below 15% in a jurisdiction.

What is the Substance-Based Income Exclusion (SBIE) under Pillar Two?

SBIE excludes a payroll carve-out (5% of tangible asset payroll costs) and a tangible asset carve-out (5% of carrying value of tangible assets) from the GloBE income base. The percentages step down over 10 years to 7.5%. SBIE rewards genuine economic substance over pure holding structures.

OECD Pillar Two Top-Up Tax 15% − ETR × Excess Profits Calculator

Calculate Qualified Domestic Minimum Top-Up Tax (QDMTT) or IIR (Income Inclusion Rule) top-up under OECD Pillar Two GloBE rules: top-up tax rate = max(0, 15% − ETR) × (income − substance-based income exclusion).

Statute of Limitations

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⚖ For informational purposes only. Not legal advice. Consult a licensed attorney for your specific situation.

How to Use

Enter the values for the scenario you are assessing. Calculate Qualified Domestic Minimum Top-Up Tax (QDMTT) or IIR (Income Inclusion Rule) top-up under OECD Pillar Two GloBE rules: top-up tax rate = max(0, 15% − ETR) × (income − substance-based income exclusion). Use the pillar two top-up tax result to inform your calculation.

OECD Pillar Two Top-Up Tax 15% − ETR × Excess Profits Calculator

Statute of Limitations

How to Use

Frequently Asked Questions

Who does Pillar Two apply to?

What is the Substance-Based Income Exclusion (SBIE) under Pillar Two?