image showing 'OECDpillars.com logo'

Pillar Two Substance Based Income Exclusion Modelling Tool

An essential element of the Pillar Two GloBE rules is the substance-based income exclusion.

It provides a degree of tax relief for MNE groups in the form of carve-outs based on the amount of qualifying payroll and tangible fixed asset costs in a jurisdiction.

Relief is to be given at 5% of the amount of qualifying costs (subject to transitional rules). This is deducted from Pillar Two net GloBE income, before calculating top-up tax. Therefore, it directly feeds into the amount of top-up tax payable. 

Our Modelling Tool allows you to adjust jurisdictional payroll and fixed asset costs to instantly see the impact this has on your top-up tax liability. 

image showing our 'substance-based income exclusion tool'

How to Access

If you’re a site member, this tool is free to use and can be accessed at:

Substance-Based Income Exclusion Modelling Tool

Instant Access

Full access to all articles, analysis, modelling tools and trackers.