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Blended CFC Calculator

For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regimes such as GILTI.

The formula allocates CFC tax under a Blended CFC Tax Regime to entities located in jurisdictions in which the GloBE Jurisdictional ETR is below the rate for the Blended CFC Tax Regime.

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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