Tax Lab · International & cross-border tax
Pillar Two GloBE ETR Calculator
A real implementation of the OECD/G20 GloBE Model Rules. Enter an entity's covered taxes, income, payroll and tangible assets, and its effective tax rate and any top-up tax owed recompute live.
The formulas are the real OECD rules, and the global context below is real and sourced. The pre-filled entities in the calculator are the prototype's own sample data, not real filings.
What Pillar Two's minimum tax actually does
The OECD/G20's Pillar Two sets a 15% effective minimum tax rate for large multinational groups (global revenue of EUR 750 million or more), jurisdiction by jurisdiction. If a group's effective tax rate (ETR) in a given country falls below 15%, a top-up tax is owed on the difference, calculated after a substance-based income exclusion (SBIE) that carves out a return linked to real payroll and tangible assets in that jurisdiction, so the rule targets paper profit shifting rather than real economic activity. Uganda currently has no domestic top-up tax (QDMTT) legislation, which means, under the rule's backstop ordering, that top-up tax on low-taxed Uganda profit can end up collected by the MNE's home country instead of by Uganda.
The global stakes
Before the calculator: real, sourced numbers on how much profit shifting the 15% minimum tax is actually up against, and how much of its own intended revenue loopholes have already carved out.
$0.0T
Multinational profit shifted to tax havens, 2022
Equivalent to 35% of all profits multinational companies booked outside their headquarters country.
0.00%
Typical effective tax rate on billionaires' wealth
A range of roughly 0-0.5% of wealth, achieved largely through shell companies that avoid income taxation entirely rather than through any legal exemption.
0.0x
Reduction in individual offshore tax evasion since AEOI
Automatic exchange of bank account information between tax authorities has cut offshore evasion by roughly a factor of three since it began, though gaps remain where institutions don't comply.
The 15% minimum tax, as designed vs. as implemented
Global corporate tax revenue the 15% minimum tax (Pillar Two) was projected to raise in 2023, with and without the substance-based and green-energy carve-outs multinationals have since used to keep effective rates below 15%. Hover a bar.
The same report proposes going further: a 2% minimum tax on billionaires' wealth, estimated to raise close to $250billion a year from fewer than 3,000 people worldwide, not an agreed policy, but a proposal from the report's own authors.
These are global figures; the EU Tax Observatory has not published a quantified Uganda-specific profit-shifting loss estimate, and this page does not invent one. Source: EU Tax Observatory, Global Tax Evasion Report 2024 (Zucman et al., October 2023), https://www.taxobservatory.eu/global-tax-evasion-report-2024/
The calculator
Edit any entity's figures, add or remove rows, switch the minimum rate or the SBIE carve-out period (the OECD's substance carve-out phases down from 10%/8% in 2023 to 5%/5% by 2033). Rows shaded red fall below the minimum rate and generate a top-up tax.
| Entity | Jurisdiction | Covered taxes ($m) | GloBE income ($m) | Payroll ($m) | Tangible assets ($m) | ETR | Top-up tax ($m) | |
|---|---|---|---|---|---|---|---|---|
| 17.1% | none | |||||||
| 13.7% | 1.5 | |||||||
| 13.0% | 2.7 | |||||||
| 13.8% | 0.3 | |||||||
| 13.6% | 1.6 |
Hover a bar. Each entity's effective tax rate against the chosen minimum rate (dashed line); red bars fall short and owe top-up tax.
Below the minimum
4 of 5 entities
Total top-up tax, rows shown
$6m
Formulas from the OECD/G20 GloBE Model Rules (2021), as stated in the prototype's README: ETR = covered taxes ÷ GloBE income; SBIE = payroll rate × payroll + asset rate × tangible assets; excess profit = GloBE income − SBIE; top-up tax = max(0, minimum rate − ETR) × excess profit. The seed rows are the prototype's own sample CbCR entries, explicitly sample data, not a real filing; GloBE income here is approximated by profit before tax, the same CbCR proxy the prototype itself uses and flags as a simplification (real GloBE income needs financial-statement adjustments under Model Rules Art. 3.1-3.5).
The formulas, exactly
GloBE ETR = Adjusted Covered Taxes ÷ GloBE Income
SBIE = (payroll rate × Payroll) + (asset rate × Tangible Assets)
Excess Profit = GloBE Income − SBIE
Top-up Rate = max(0, Minimum Rate − GloBE ETR)
Top-up Tax = Top-up Rate × Excess Profit
Uganda's QDMTT question
The prototype's own documentation estimates Uganda's annual QDMTT potential at roughly USD 40-100 million, varying by scenario, if Uganda enacted a domestic minimum top-up tax to collect this revenue itself rather than ceding it to an MNE's home jurisdiction under the EU's IIR (Directive 2022/2523) or similar rules elsewhere. That range is the prototype's own estimate, not independently verified here; this calculator lets you see how the same formulas behave on whatever entity figures you enter.
Limitations, stated by the prototype itself
- Uses CbCR data as a GloBE income proxy; real GloBE income needs financial-statement adjustments under Model Rules Art. 3.1-3.5.
- Does not model deferred tax assets/liabilities in full.
- Does not apply the Transitional CbCR Safe Harbour rules.
- Sample data only; replace with official OECD CbCR submissions for real policy use.
Sources: OECD (2021), Tax Challenges Arising from the Digitalisation of the Economy: Global Anti-Base Erosion Model Rules (Pillar Two), Articles 2.1 (minimum rate), 1.1 (revenue scope), 5.1 (de minimis), and the SBIE carve-out schedule. OECD Country-by-Country Reporting Table I statistics. EU Tax Observatory, Global Tax Evasion Report 2024 (Zucman et al., October 2023), for the global profit-shifting and minimum-tax figures above.