Global IP Tax Incentives Tool

Tax incentives are a key determining factor for the Pillar Two GloBE effective tax rate (ETR).

Not all tax incentives have the same impact on the GloBE ETR/top-up tax, as is shown in this table.

Tax Incentive	Type	Impact of the GloBE Rules	Effect on GloBE covered tax	Effect on GloBE income
Income-based incentive	Full exemption	Very likely	Decrease
Income-based incentive	Partial exemption	More likely	Decrease
Income-based incentive	Reduced rate	More likely	Decrease
Expenditure-based incentive	Tax allowance	More likely	Decrease
Expenditure-based incentive	Bonus depreciation/accelerated depreciation: tangible assets	Unaffected	No recapturing
Expenditure-based incentive	Bonus depreciation/accelerated depreciation: short lived intangibles	Less likely	Recapturing may apply
Expenditure-based incentive	Bonus depreciation/accelerated depreciation: other assets	More likely	Recapturing may apply
Expenditure-based incentive	Qualifying refundable tax credit	Less likely		Increase
Expenditure-based incentive	Other tax credit	More likely	Decrease

Global tax incentives for intellectual property (IP) have grown significantly in recent years. The impact on any top-up tax will depend (amongst others) on the type of tax incentive, jurisdictional blending and the substance-based income exclusion.

Our Global IP Tax Incentives Tool provides high level analysis of IP tax incentives globally, including the tax rate reduction.

Choose up to 4 jurisdictions to compare the respective regimes.

Sign into your account to access this tool

Not a Subscriber?

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

Already a Subscriber?

Lee Hadnum

Lee is a qualified Chartered Accountant and 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.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

IIRs and DMTTs that don’t yet Qualify Under the OECD March 2025 Update

Poland to Issue a Draft Bill to Implement Aspects of the OECD Administrative Guidance

UAE Issues Ministerial Decision to Implement the OECD Administrative Guidance