An entity (whether that is the UPE, intermediate parent company or a POPE) that is required to account for top-up tax under an Income Inclusion Rule (‘IIR’), is generally taxed on its ‘allocable share’ of the low tax entity’s top up tax.
Use our members Income Inclusion Rule Calculator to see how the IIR applies.
Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company.
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