image showing 'OECDpillars.com logo'

Comprehensive Data Points for the Substance-Based Income Exclusion

The substance-based income exclusion is effectively a carve-out for expenditure on tangible fixed assets and payroll costs. The amount of the exclusion feeds directly into the top-up tax calculation as it reduces excess profits which are then used to calculate the initial top-up tax.
 
In this article we take a comprehensive look at how the substance-based income exclusion applies including the various adjustments for permanent establishments and flow-through entities and the data points required. 

Payroll

Sign into your account to access this analysis

Not a Subscriber?

If you haven’t got a subscription you can join up below.

Already a Subscriber?