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Pillar Two: GILTI & Blended CFC Regimes

Pillar Two: GILTI & Blended CFC Regimes

Article 2.10 of the Administrative Guidance provides more information on the treatment of the US Global Intangible Low-Taxed Income (GILTI) regime.

This is to be treated as a blended CFC Regime for GloBE purposes. Under the GloBE Rules CFC taxes are allocated to the foreign CFC (subject to the push down restriction). The GloBE Commentary doesn’t go into detail on the allocation and just provides that the CFC tax should be allocated to each CFC based on the owner’s share of the underlying income.

However, determining the allocation can be tricky when there is a blended CFC regime.

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