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.
Sign into your account to access this tool
Not a Subscriber?
If you haven’t got a subscription you can join up below.
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.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution