Top-up Tax

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Tax - profit shifting - Global Minimum Tax - Organisation for Economic Co-operation and Development (OECD) - Pillar 2.

Additional tax payable under the OECD Pillar 2 rules, to ensure that large multinational entities are subject to a global minimum tax rate.


Topping up to a 15% effective tax rate
"Pillar 2 will require calculation of specific effective tax rates by territory: where this is below 15%, a top-up tax will arise. Where a territory does not collect this tax (for example, if it does not implement the rules), it is collected by other territories in which the group operates.
Therefore, most territories are expected to implement Pillar 2, because the alternative is to give away tax revenues to others."
Graham Robinson, international tax and treasury partner PwC & Iain McDonald international tax and treasury director PwC - The Treasurer, Issue 4 2022 - December 2022, p40.


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