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Pillar Two: Pension Funds

Pillar Two: Pension Funds

Pension funds are subject to a number of specific provisions under the Pillar Two rules. In this article we look at some of the key aspects of Pillar Two that impact on Pension Funds. 

Excluded Entities

Article 1.5.1 of the Model Rules provides that a Pension Fund and certain other related entities are excluded entities for Pillar Two purposes.

This is important as excluded entities are not subject to top-up tax or any obligation to apply an income inclusion rule or under-taxed payments rule.  However, excluded entities are still taken into account for the purposes of determining whether the MNE group has exceeded the 750 million consolidated revenue threshold.  

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