15% Global Minimum Tax: OECD GloBE rules apply to MNEs with revenue ≥ €750M
Top-up tax = (15% − ETR) × GloBE Income when ETR < 15%. This calculator provides a simplified estimate.
What is Pillar Two (GloBE)?
Pillar Two is part of the OECD/G20 BEPS project. It introduces a 15% global minimum effective tax rate for multinational enterprises (MNEs) with consolidated group revenue of at least €750 million. The GloBE (Global Anti-Base Erosion) rules ensure each jurisdiction where an MNE operates has an ETR of at least 15%. If lower, a top-up tax is due.
Pillar Two is implemented in the EU via the Minimum Tax Directive (2022/2523) and in many other jurisdictions from 2024 onward.
Pillar Two Formula
ETR = Covered Taxes ÷ GloBE Income
Top-Up Tax = max(0, (15% − ETR) × GloBE Income)
When ETR is at or above 15%, no top-up tax is due. When ETR is below 15%, the shortfall is multiplied by GloBE income.
Example
GloBE Income: €1,000,000 | Covered Taxes: €100,000 → ETR = 10%
Top-Up = (15% − 10%) × €1,000,000 = €50,000
GloBE Income and Covered Taxes
GloBE income is financial accounting profit (or loss) with specific adjustments under the OECD Model Rules. Covered taxes are income taxes paid or accrued in the jurisdiction that count toward the ETR. Real GloBE calculations include substance-based carve-outs, qualified refundable tax credits, and other adjustments—our calculator gives a simplified estimate.
IIR, UTPR, and QDMTT
Top-up tax can be collected via: Income Inclusion Rule (IIR)—parent jurisdiction taxes low-taxed income; Undertaxed Profits Rule (UTPR)—denies deductions or imposes equivalent tax where IIR does not apply; Qualified Domestic Minimum Top-up Tax (QDMTT)—jurisdiction taxes its own low-taxed income first.
Official resources
MNEs with consolidated revenue ≥ €750M in at least two of the four preceding fiscal years.
Exclusions: government entities, international organisations, pension funds, investment funds (in some cases).
15% effective tax rate per jurisdiction. Top-up applies when ETR < 15%.
EU: from 2024 (IIR, UTPR 2025). UK, Switzerland, Japan, Canada, Australia and others have adopted or are adopting GloBE.