Investment companies are treated differently to other companies, for the purposes of the Pillar Two GloBE Rules. 

Importantly, there are subject to separate jurisdictional blending requirements and only the allocable share of the groups ownership interest is taken into account when calculating the jurisdictional effective tax rate. 

This can lead to multinationals with investment entities in a jurisdiction being subject to more than one effective tax rate calculation, and can impact on the amount of top-up tax payable. 

Our Pillar Two Investment Entities Calculator models the impact of a mix of investment and non-investment companies on both the effective tax rate and top-up tax payable.