Once the top-up tax for the jurisdiction has been calculated, it is then allocated to the constituent entities in the jurisdiction that have net Pillar Two GloBE income (ie not entities that have Pillar Two GloBE losses) so that the charging provisions (ie the income inclusion rule or under-taxed payments rule) can correctly apply.
Note, that if all of the constituent entities in the jurisdiction are wholly owned and the UPE is applying an income inclusion rule, the allocation amongst constituent entities wouldn’t be required given the UPE would simply account for the top-up tax.
Article 5.2.4 of the OECD Model Rules provide that the allocation is based on each relevant constituent entity’s share of the total net Pillar Two GloBE income of the jurisdiction.
Example
In jurisdiction X:
Company A has net Pillar Two GloBE income of 5 million
Company B has net Pillar Two GloBE income of 10 million
Company C has net Pillar Two GloBE income of 20 million
Company D has a net Pillar Two GloBE loss of 5 million
Total jurisdictional top-up tax is 5 million. This is allocated as follows:
Company A = 5 million * 5/35 = 714,286
Company B = 5 million * 10/35 =1,428,571
Company C = 5 million * 20/35 =2,857,143
Company D = 0
On December 18, 2025, the Irish Revenue issued Revenue eBrief No. 244/25 which provides for an extension in the Pillar 2 registration deadline to February 28, 2026 (from December 31, 2025).
On December 19, 2025, the Luxembourg Official Gazette published:
– a law to amend its Minimum Tax Law to provide for the January 2025 OECD Administrative Guidance and the EU DAC 9 GIR filing requirements: and
– a Grand Ducal Regulation which includes the format of the GIR
On December 19, 2025, SARS issued further guidance on the Pillar 2 registration process.
Order No. 158/2025 XXV issued on December 12, 2025 provides that for constituent entities whose fiscal year ended between December 31, 2024 and March 31, 2025 the filing deadline for Form 62 (the Pillar 2 Registration Form) is the last day of the 15th month following the end of that fiscal year.
On December 16, 2025, The Netherlands Parliament approved the Second Amendment to the Minimum Tax Act to implement the December 2023, June 2024 and January 2025 OECD Administrative Guidance.
On December 10, 2025, Law No. SFS 2025:1461 to amend the Global Minimum Tax Act was published in the Swedish Official Gazette. The purpose of the law is to implement the provisions of the June 2024 OECD Administrative Guidance into domestic law.
On November 25, 2025, the Finnish Tax Administration published guidance on the allocation of profits/losses and taxes between group entities to take account of the June 2024 OECD Administrative Guidance.
On November 26, 2025, Montenegro issued a Draft Law to apply a domestic minimum top-up tax (DMTT) from January 1, 2026.
On December 1, 2025, Turkey announced an extension in the filing and payment date for the QDMTT return and the opening of a test environment for the submission of the QDMTT return.
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