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Restructuring an MNE Group to Maximize Pillar Two Tax Efficiency

Minority owned sub-groups (defined as a minority owned parent entity and its minority owned subsidiaries) are treated as a separate MNE group. Therefore, the adjusted covered taxes and GloBE income of the minority owned sub-group are excluded from the jurisdictional GloBE ETR calculation for the rest of the MNE group and any top up tax is calculated separately.

A minority owned entity is an entity where the UPE owns 30% or less of the ownership interest but the UPE holds the controlling interest. The 30% ownership test takes account of both direct and indirect ownership.

This can result in an MNE group having to calculate more than one ETR in a jurisdiction.


UPE is the ultimate parent entity of an MNE group within the scope of the Pillar Two GloBE rules. It has a group structure of:

image showing 'example group structure for minority owned subgroup example'