Pillar Two & Global Minimum Tax
GloBE rules, IIR/UTPR/QDMTT, ETR and SBIE, the transitional safe harbour and CbCR’s role in Pillar Two compliance.
Pillar Two Explained: The 15% Global Minimum Top-Up Tax (2026)
Pillar Two in one guide: why the 15% global minimum tax, the €750 mn scope, the three charging mechanisms at a glance, who is affected, and the position in the key jurisdictions including India.
Read docGloBE Rules: How the Calculation Actually Works
The GloBE computation step by step: the consolidated CbC group, the adjusted covered income, the covered taxes, the jurisdictional ETR, the SBIE carve-out, and a worked top-up tax example.
Read docIIR, UTPR and QDMTT: The Three Charging Mechanisms
How the top-up tax is charged: the IIR (the parent’s inclusion), the UTPR (the backstop), the QDMTT (the jurisdiction’s own top-up) — priority order, allocation mechanics, and a worked allocation.
Read docEffective Tax Rate and SBIE: The Exclusions That Matter
The jurisdictional ETR’s two halves: the covered taxes numerator and the adjusted covered income denominator, the SBIE carve-out (the payroll and tangible-asset credits), and a worked exclusion.
Read docTransitional CbCR Safe Harbour: The 3-Year Fast-Path Test
The transitional CbCR safe harbour: the 3-year fast path that clears a jurisdiction from the top-up where its CbCR ETR is at or above 15% — the test, the scope conditions, and the safe harbour.
Read docHow CbCR Data Powers Pillar Two Compliance
Why the CbCR is the Pillar Two data backbone: the shared €750 mn scope, the CbCR rows as the computation inputs, and the reconciliation that keeps the three tiers consistent.
Read docEU Public CbCR (Directive 2021/2101): What Gets Published
The EU public CbCR regime under Directive 2021/2101: the published data (jurisdictional profile, parent information, machine-readable format) and what it means for the group’s TP posture.
Read docWhat Pillar Two Means for TP Teams: Workflow and Data Checklist
How GloBE changes transfer pricing work: the new data duties, the pricing-to-ETR interaction, the documentation touchpoints and the team action checklist.
Read docBrowse other sections
Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.