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The Impact of the Different ETR Calculation for Investment Funds

The Pillar Two effective tax rate (ETR) calculation for investment entities is similar to the standard ETR calculation, however, there is an important twist. 

ETR Calculation, Generally
Generally, the ETR is calculated as Adjusted Covered Taxes/GloBE Income. This is then deducted from the 15% global minimum rate to calculate the ‘top-up tax percentage’.  
 
GloBE income is then reduced by any Substance-Based Income Exclusion and the initial top-up tax is calculated by applying the top-up tax percentage.  There is then a further adjustment for any additional top-up tax (eg from a previous year) or any tax imposed under a qualifying domestic minimum top-up tax. 
 
Importantly, when calculating the ETR, the adjusted covered taxes and GloBE income are not reduced for any minority interest. For example, if a UPE held 90% of the interest in a low-taxed subsidiary, there is no reduction for the 10% interest held by the minority owner and 100% of the tax and income attributable to the entity are used to calculate the Pillar Two ETR. 
 
The reason for this is that the minority interest is taken into account when the top-up tax is allocated to another group entity for payment of the top-up tax under the income inclusion rule or under-taxed payments rule. In the example above, for instance, the UPE would be allocated 90% of the top-up tax. 
 
Investment Entity ETR Calculation
 
However, this does not apply to investment entities as minority interests are taken into account when calculating the ETR and the top-up tax. 

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image showing group structure for investment entities ETR example

group structure for example 2 showing the ETR for investment entities

Lee Hadnum

Lee Hadnum

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.

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