beps-pillar-two-assessment

What problem does it solve?

It helps you evaluate whether a multinational group is subject to OECD Pillar Two rules and estimate the resulting Top-up Tax by jurisdiction.

Core Features & Use Cases

• ETR analysis by jurisdiction: Computes Effective Tax Rate using adjusted covered taxes over GloBE income or loss, with key inclusions and exclusions.
• SBIE and Excess Profit calculation: Estimates Payroll and Tangible Asset carve-outs (SBIE) to derive Excess Profit and then Top-up Tax.
• Rule applicability assessment (IIR/UTPR/QDMTT): Reviews how the group would be affected across the different mechanisms, including priority and safe-harbor/transition concepts.
• Use Case: When preparing a transfer-pricing/tax compliance package, use it to quantify which low-tax jurisdictions may generate top-up amounts and what governance/administration steps are needed.

Quick Start

Use the beps-pillar-two-assessment skill to produce a Pillar Two GloBE impact report for your group, including ETR, SBIE, Excess Profit, Top-up Tax, and an IIR/UTPR/QDMTT applicability analysis for the selected year.