UPE Data Points for the GloBE Information Return

The corporate structure information is relevant for applying the GloBE Rules and identifying not only which constituent entities are subject to the GloBE Rules and required to pay top-up tax, but also who, where and how top-up tax is paid.

The information required to be reported for the corporate structure can be split into three elements:

– Information on the Ultimate Parent Entity (UPE); 

– Information on group entities; and

– Information relating to any changes to the group structure during the relevant year.

In this first of a series of articles that will break down all of the data points for the purposes of the Pillar Two GloBE rules (and in particular the expected reporting in the GloBE information return), we look at the UPE aspect of the corporate structure.


The key data points for the UPE include:

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