Pillar 2: Applying the legislation - 02

[@happygolucky2577]

Very brilliant analysis

[@buredtx]

Thank you for sharing!

[@chshchi]

I think the UTPR has been revamped. It does not have to be taxed under a denial of intra-group payment. It simply allocates the top-up tax amount which is not caught by an IIR (18.5 in your first case) to all the UTPR jurisdiction. Assuming both 5% CIT country and 25% CIT country has implemented the GloBE rules, the 18.5 will be shared between these two countries based on the UTPR allocation factor (50% employees and 50% tangible asset). It is then up to the country as to how to tax and collect the top-up tax.

[@happygolucky2577]

Hatts off to you sir