Top-up Tax

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.

See also

• Base erosion and profit shifting (BEPS)
• Corporation Tax
• Effective tax rate (ETR)
• Global Anti-Base Erosion Rules (GloBE)
• Global minimum corporate tax rate
• Income Inclusion Rule (IIR)
• Income Tax
• Multinational corporation/company
• Nexus rule
• Organisation for Economic Co-operation and Development (OECD)
• Parent company
• Pillar 1
• Pillar 2
• Profit shifting
• Regime
• Sister company
• Subject To Tax Rule
• Tax
• Tax avoidance
• Tax compliance
• Tax evasion
• Tax haven
• Tax rate
• Transfer pricing
• Undertaxed Payments Rule (UTPR)

External links

• OECD - Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) - Commentary
• Pillar Two rules in a nutshell - OECD