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 IncentiveType Impact of the GloBE RulesEffect on GloBE covered taxEffect on GloBE income
Income-based incentiveFull exemptionVery likely Decrease
Income-based incentivePartial exemptionMore likelyDecrease
Income-based incentiveReduced rateMore likelyDecrease
Expenditure-based incentiveTax allowanceMore likelyDecrease
Expenditure-based incentiveBonus depreciation/accelerated depreciation: tangible assetsUnaffectedNo recapturing
Expenditure-based incentiveBonus depreciation/accelerated depreciation: short lived intangiblesLess likely Recapturing may
Expenditure-based incentiveBonus depreciation/accelerated depreciation: other assetsMore likelyRecapturing may
Expenditure-based incentiveQualifying refundable tax creditLess likely Increase
Expenditure-based incentiveOther tax creditMore likelyDecrease

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. 

Global IP Tool

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