Use this tool to understand the calculation and explore an initial estimate. It cannot prepare a tax return or confirm eligibility for relief. You still need to check the group’s scope, the required data adjustments and the applicable local law.
Indicative Calculator
About this calculator
Calculate indicative jurisdictional top-up tax from GloBE-adjusted figures, including the substance-based income exclusion, domestic minimum top-up tax, the transitional CbCR and QDMTT safe harbours and the de minimis exclusion. Every step shows its working and the rule it applies.
Calculator options
Inputs
Jurisdiction and period
GloBE income and taxes
Enter jurisdiction totals already adjusted under the GloBE rules. The engine does not make these adjustments.
Use a minus sign for a net GloBE loss.
From recalculations of earlier years (Art. 5.4). The standard worksheet does not model negative adjusted covered taxes; the separate Simplified ETR worksheet has a loss and negative-tax adjustment branch.
Substance-based income exclusion
For eligible employees working in the jurisdiction (Art. 5.3.3).
Average of opening and closing carrying values (Art. 5.3.4). Excludes property held for sale, lease or investment.
Domestic minimum top-up tax
Safe harbours and exclusions
2026 safe-harbour elections
Use the selected fiscal year and calculation currency. Elections do not automatically establish legal eligibility. Enter amounts prepared under the applicable rules, not unadjusted accounts.
The Transitional CbCR simplified ETR test uses its own transition rates and qualifying CbCR data. The separate Simplified ETR Safe Harbour uses prepared Simplified Income and Simplified Taxes and a 15% threshold. Their inputs, eligibility and commencement conditions are different.
OECD Side-by-Side package (January 2026)Parent share
Simplified share of the top-up tax picked up by a parent applying an Income Inclusion Rule.
Results
Your estimate will appear here
Enter your fiscal year and prepared GloBE figures, then select View results. You can also start with a fictional example.
Rules appliedas at 29 October 2026
The rules date is when these parameters were last reviewed against the listed sources. It does not mean every current rule is implemented: only the rules in this register are modelled, and domestic law may differ.
| Rule | Value applied | Reference | Source and date |
|---|---|---|---|
| Minimum rate | 15% | Art. 5.2.1 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Effective tax rate | Adjusted covered taxes ÷ net GloBE income | Art. 5.1.1 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Top-up percentage | Minimum rate − ETR, not less than zero | Art. 5.2.1 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Excess profit | Net GloBE income − SBIE, not less than zero | Art. 5.2.2 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Jurisdictional top-up tax | Top-up % × excess profit + additional − QDMTT, not less than zero | Art. 5.2.3 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Additional current top-up tax | Added, including where ETR ≥ 15% | Art. 5.4 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| SBIE, permanent rates | 5% payroll; 5% tangible assets | Art. 5.3.3, 5.3.4 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| SBIE, transitional rates | Payroll 10.0% (2023) to 5.8% (2032); assets 8.0% (2023) to 5.4% (2032) | Art. 9.2.1, 9.2.2 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021); Consolidated Commentary to the GloBE Model Rules (2026) (May 2026) |
| De minimis exclusion | Average revenue < EUR 10m and average GloBE income < EUR 1m | Art. 5.5 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| IIR allocable share | Top-up tax × inclusion ratio (simplified) | Art. 2.1, 2.2 | Global Anti-Base Erosion Model Rules (Pillar Two) (20 Dec 2021) |
| Transitional CbCR safe harbour: availability | Fiscal years beginning on or before 31 December 2027 and ending on or before 30 June 2029; qualified CbCR and financial statements; continuity conditions apply | Safe harbours, s. 1; Side-by-Side package, ch. 3 | Safe Harbours and Penalty Relief (20 Dec 2022); Side-by-Side package (Jan 2026) |
| Transitional CbCR safe harbour: tests | De minimis; simplified ETR 15% (2023–24), 16% (2025), 17% (2026–27); routine profits | Safe harbours, s. 1; Side-by-Side package, ch. 3 | Safe Harbours and Penalty Relief (20 Dec 2022); Side-by-Side package (Jan 2026) |
| Simplified covered taxes | Excludes non-covered taxes and uncertain tax positions; hybrid arbitrage flagged | Safe harbours; AG | Safe Harbours and Penalty Relief (20 Dec 2022); Administrative Guidance, December 2023 (18 Dec 2023) |
| QDMTT safe harbour | Top-up tax deemed zero for IIR and UTPR purposes where it applies (entered, not tested); local QDMTT obligations continue | QDMTT safe harbour | Administrative Guidance, July 2023 (17 July 2023) |
| Simplified ETR safe harbour | 15% ETR or a Simplified Loss; prepared inputs and eligibility confirmations required | OECD 2026, Chapter 2 | Side-by-Side package (Jan 2026) |
| Substance-based Tax Incentive (SBTI) safe harbour | QTI capped at 5.5% of the greater of payroll or depreciation; alternative 1% asset election | OECD 2026, Chapter 4 | Side-by-Side package (Jan 2026) |
| Side-by-side system | IIR and UTPR relief only; QDMTT unaffected; recognised regime and election required | OECD 2026, Chapter 5 | Side-by-Side package (Jan 2026) |
| UPE safe harbour | UTPR relief only on the UPE jurisdiction; no IIR or QDMTT exemption | OECD 2026, Chapter 5 | Side-by-Side package (Jan 2026) |
The 2026 safe-harbour worksheet calculates relief from prepared inputs and confirmed eligibility. Other guidance and domestic-law adjustments may affect the result.
What this calculation does not do
- Testing whether the group is within scope (the consolidated revenue test)
- Negative adjusted covered taxes in the standard worksheet (Art. 4.1.5 and related guidance). The separate Simplified ETR worksheet displays a loss-related negative-tax adjustment but does not maintain multi-year balances.
- Period limits: the standard worksheet accepts 364–371 days, including 52- and 53-week years; the 2026 worksheet accepts only 365–366 days. Other lengths are refused; short-period adjustments are not modelled.
- Computing GloBE income or adjusted covered taxes from accounts
- Allocating top-up tax between entities in a jurisdiction (Art. 5.2.4)
- Minority-owned entities, joint ventures and investment entities
- The Undertaxed Profits Rule
- Deferred tax liability recapture and other recalculations
- Later guidance on explicitly conditional taxes and QDMTT accounting-period mismatches, and the September 2026 GIR changes
- Testing whether the QDMTT safe harbour applies
How to use the result
This calculation uses GloBE-adjusted inputs. It does not determine final tax payable, allocate collecting rights or complete a filing. Check the input assumptions and applicable law before using the result.
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