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Pillar Two Tracker

Pillar Two - Substance-Based Exclusion Calculator

This simple substance-based exclusion calculator gives an indication on the broad operation of the substance-based exclusion calculation, and in particular the impact that it has on the top-up tax calculation. 

The substance-based income exclusion has a significant interaction with tax incentives. Tax incentives are one of the key drivers for a low effective tax rate (ETR).

For more information, see our report on Tax Incentives and Pillar Two.

For more detailed Pillar Two modelling tools, including multiple years, unlimited companies and the impact of elections, see our Pillars Modelling Tools.

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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.

This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution

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