What is Top-up Tax?
Top-up tax is a mechanism intended to ensure that MNEs pay a minimum ETR of 15% in each jurisdiction in which they operate. Based on GloBE Rules, the ETR is the total covered taxes divided by the total profit in the jurisdiction. If the MNE’s ETR goes below the minimum in a jurisdiction, a top-up tax amount will be imposed to bring it up to 15%. This top-up tax can be collected through several mechanisms, including Multinational Top-Up Tax (MTT) and Domestic Top-Up Tax (DTT).
A - MAIN REFERENCE MATERIALS
- Model GloBE Rules (Published 20 December 2021)
- Commentary to the GloBE Rules - First Edition (Published 14 March 2022)
- GloBE Rules Examples (Published 14 March 2022)
- Safe Harbours and Penalty Relief (Published 20 December 2022)
- Agreed Administrative Guidance on the GloBE Rules (Published 2 February 2023)
- Agreed Administrative Guidance on the GloBE Rules (Published 17 July 2023)
- GloBE Information Return(Published 17 July 2023)
- Minimum Tax Implementation Handbook (Published 11 October 2023)
- Administrative Guidance on the Global Anti-Base Erosion Model Rules (Published 18 December 2023)
B - SUPPLEMENTARY REFERENCE MATERIALS
- Summary : Pillar Two Model Rules In A Nutshell
- Pillar Two Model Rules Fact Sheets
- Global Anti-Base Erosion Model Rules Frequently Asked Questions
CONTACT US :