Pillar Two€ 49 / calculation

Work through Pillar Two — ETR, SBIE and top-up tax per jurisdiction

Test the € 750 million revenue threshold across four years, apply the transitional CbCR safe harbours per jurisdiction, and compute the effective tax rate, the substance-based income exclusion and the top-up tax that follows — with the QDMTT offset and the net IIR amount per jurisdiction and for the group as a whole.

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gir-pillar-two v1.0.1 · vintage client-2026-07 · draft free

Example outcome

Net IIR top-up€ 463,662

Gross top-up — 3 jurisdictions, FY2024€ 4,243,662

QDMTT paid — offset against the top-up€ 3,780,000

Ireland — ETR 12.5%, exclusion € 6,260,000€ 293,500

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Who it’s for

01Tax directors of multinational groups who need to know per jurisdiction where top-up arises and how much a QDMTT absorbs.

02Pillar Two specialists in advisory firms who want to recompute a GloBE calculation and test the safe harbour routes.

03Group controllers and reporting teams preparing the figures for the GloBE Information Return and reconciling them per jurisdiction.

What the tool does

✓ A scope test on the € 750 million revenue threshold in at least two of the four years entered, with the excluded entity types✓ The three transitional CbCR safe harbours per jurisdiction: de minimis, simplified ETR and routine profits✓ GloBE income from the financial result plus adjustments, and covered taxes from current, deferred and adjusted items✓ A substance-based income exclusion following the Article 9.2 phase-down, per fiscal year with its own payroll and tangible asset percentages✓ Effective tax rate, excess profit and top-up tax per jurisdiction, with the QDMTT offset and the remaining IIR amount✓ Group totals: gross top-up, QDMTT paid and net IIR, with the charging mechanism applied per jurisdiction

01 — Form

Case and key figures — a handful of fields.

02 — Draft

Full outcome layout, free.

03 — Pay € 49

Via Mollie, VAT/VIES handled.

04 — Report

Certified PDF + public hash.

The safe harbour is the first question, not the last

Within the transition window, a jurisdiction that meets one of the three CbCR safe harbours does not need a full GloBE calculation: the top-up is then zero. That makes the order of analysis matter. Only when none of the three tests passes do the effective tax rate, the substance-based income exclusion and the excess profit come into play — and only then does it become visible how much top-up actually arises and which mechanism absorbs it.

Then the offset matters. A jurisdiction with a qualified domestic minimum top-up tax absorbs the charge locally; what remains reaches the parent through the income inclusion rule. The tool computes all jurisdictions in one pass, shows the effective rate, the exclusion, the excess profit and the mechanism per row, and adds gross top-up, QDMTT paid and net IIR into group totals. Every report states the fiscal year, the percentages used, the tool version and the dataset vintage, so the calculation is exactly reproducible later.

Frequently asked questions about this tool

Does the calculation stop if the group is out of scope?

No. The scope test yields a separate outcome — in scope, to be checked, out of scope, or no outcome if you enter no revenue figures — but the per-jurisdiction calculation runs in every case. That is deliberate, so you can model a scenario. Read the scope outcome as an answer in its own right, not as a gate on the rest of the report.

Which minimum rates does the top-up calculation use?

For fiscal years 2023 and 2024 it is 15%. For 2025 through 2027 the calculation uses the simplified ETR test threshold (16% and 17% respectively) as the minimum rate, and from 2028 — once the transition window has closed — it applies a flat 15% to the excess profit regardless of the effective tax rate. Both diverge from the 15% GloBE minimum rate and both appear as explicit warnings in the report, so you know which outcomes to check against the legislative text.

How does the QDMTT offset work?

The qualified domestic minimum top-up tax you enter per jurisdiction is deducted from the computed top-up; what remains is the IIR amount, floored at zero. The deduction applies to any jurisdiction where you enter an amount, including one not flagged as a QDMTT jurisdiction in the list — so leave the field at zero there. If you pay more than the computed top-up, the tool raises a flag.

Is the QDMTT list current?

The jurisdiction list and its QDMTT status come from the dataset vintage and are marked indicative there. Check the status of your jurisdictions against the OECD Central Record before using the outcome; the flag drives the charging mechanism shown. The report states which vintage was used, so it stays recognisable later which state the outcome rests on.

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