Pillar 2. Allocating UTPR income

[@chshchi]

I think this is broadly correct, noting the following:- (1) UTPR (with P stands for Payment) - in the Oct 2020 Blueprint it was designed to adjust intra-group payment, however, I believe that this has been completely changed. It is now a mechanical rule to allocate Top-Up tax (which is not caught by IIR) to all relevant countries. In fact, if you read the HMRC consultation papers, it says UTPR now stands for Undertaxed Profits Rule. (2) In your case, the country with 5% CIT rate is also eligible to "share" some top-up tax based on the employees/assets located in that jurisdiction. (3) Even if there is no intra-group transaction, say FinCo itself is an Opco but it is undertaxed in the jurisdiction. The top-up tax will still be allocated among the UTPR jurisdictions using the same mechanism.

[@happygolucky2577]

Excellent is small word after watching this. Thanks a ton...!!!