Skip to content This library is free, offered as dana. If it helps your work, donate here →

This is one of 3,622 free prompts in the penguin tree ai library. Sign up once and the whole library opens, with new prompts by email.

open the library →

Pillar two global minimum tax impact calculator

Computes estimated Pillar Two top-up tax exposure from jurisdiction-level financial data under OECD GloBE rules — calculating GloBE ETR per jurisdiction, applying the substance-based income exclusion, flagging…

download .md

Purpose

Convert jurisdiction-level financial and tax data into an estimated Pillar Two top-up tax exposure — calculating the GloBE effective tax rate per jurisdiction, netting the substance-based income exclusion, and identifying exactly which jurisdictions push the group below the 15% minimum and how much top-up tax results. Replaces error-prone spreadsheet modeling with a repeatable, rule-aligned calculation the tax function can run each time entity data updates.

When to Use

Invoke this skill when the user asks to:

  • Estimate Pillar Two / GloBE top-up tax exposure across a multinational group
  • Determine which jurisdictions fall below the 15% global minimum tax rate
  • Calculate the substance-based income exclusion (SBIE) offset for a jurisdiction
  • Model the tax impact of Pillar Two before filing or board reporting
  • Assess whether a low-tax jurisdiction triggers Income Inclusion Rule (IIR) or UTPR liability
  • Stress-test restructuring or investment scenarios against the global minimum tax

Inputs Required

Before starting, collect:

  • Jurisdictions in scope: List of jurisdictions where constituent entities operate
  • GloBE income per jurisdiction: Net accounting income adjusted for GloBE (financial accounting profit before tax as a starting point if adjustments unknown)
  • Covered taxes per jurisdiction: Current + deferred tax expense attributable to each jurisdiction
  • Payroll costs per jurisdiction: Eligible employee compensation for the SBIE carve-out
  • Tangible assets per jurisdiction: Net book value of eligible tangible assets for the SBIE carve-out
  • Ownership / group structure: Which parent(s) hold the low-tax entities — to determine whether IIR, UTPR, or a QDMTT applies
  • Fiscal year: The reporting period — determines the applicable SBIE transition rate

If GloBE adjustments are unavailable, use financial-accounting profit before tax as the income proxy and covered taxes as reported income tax expense, and flag these as unadjusted estimates. If ownership structure is not provided, assume top-up tax is collected via the IIR at the ultimate parent.

Instructions

Step 1: Confirm Scope and Assumptions

  • Confirm the group meets the €750M consolidated revenue threshold; if unknown, note that Pillar Two applies only at or above this threshold and proceed as if in scope.
  • State the fiscal year and the corresponding SBIE transition percentages (see Step 4).
  • List every jurisdiction to be calculated and confirm each has income, covered taxes, payroll, and tangible asset figures. Flag any jurisdiction with missing data.

Step 2: Calculate GloBE ETR per Jurisdiction

For each jurisdiction:

  • GloBE ETR = Adjusted Covered Taxes ÷ Net GloBE Income
  • Aggregate all constituent entities within the same jurisdiction (jurisdictional blending) before computing the ratio — do not calculate entity-by-entity.
  • Express the ETR as a percentage to one decimal place.
  • Where net GloBE income is zero or negative, note that no top-up tax arises for that period and set aside for the loss-carryforward note in Step 8.

Step 3: Flag Low-Tax Jurisdictions

  • Compare each jurisdictional GloBE ETR to the 15% minimum rate.
  • Mark each jurisdiction: Above 15% (no top-up) or Below 15% (at risk).
  • For each at-risk jurisdiction, compute the Top-up Tax Percentage = 15% − GloBE ETR.

Step 4: Calculate the Substance-Based Income Exclusion (SBIE)

The SBIE reduces the income subject to top-up tax by a percentage of payroll and tangible assets. For each at-risk jurisdiction:

  • SBIE = (Payroll Carve-out % × Eligible Payroll) + (Tangible Asset Carve-out % × Net Tangible Assets)
  • Apply the transition-year rates for the fiscal year in scope:
  • Steady state (2033+): 5% payroll / 5% tangible assets
  • Transition schedule declines annually from higher rates (e.g., ~9.8% payroll / ~7.8% assets in early years) toward 5% — apply the rate matching the stated fiscal year and cite the rate used.
  • Excess Profit = Net GloBE Income − SBIE (floor at zero; if SBIE ≥ income, top-up tax is zero for that jurisdiction).

Step 5: Compute Top-up Tax per Jurisdiction

For each at-risk jurisdiction:

  • Top-up Tax = Top-up Tax Percentage × Excess Profit
  • Subtract any Qualified Domestic Minimum Top-up Tax (QDMTT) already imposed locally — if a QDMTT applies in that jurisdiction, the residual top-up tax collected under IIR/UTPR is typically reduced to zero. Note QDMTT status per jurisdiction.

Step 6: Assign the Collection Mechanism

For each jurisdiction with residual top-up tax, determine who collects it based on the group structure:

  • QDMTT: Collected locally in the low-tax jurisdiction (takes priority).
  • IIR: Collected at the ultimate/intermediate parent under the Income Inclusion Rule.
  • UTPR: Backstop where no IIR applies — allocated across UTPR jurisdictions. Label each exposure with its collecting mechanism and paying entity.

Step 7: Build the Ranked Exposure Summary

  • Rank at-risk jurisdictions by absolute top-up tax, largest first.
  • Present a table with: Jurisdiction | GloBE Income | Covered Taxes | GloBE ETR | SBIE | Excess Profit | Top-up % | Top-up Tax | Collection Mechanism.
  • Total the group-level top-up tax exposure.

Step 8: Mitigation Levers and Sensitivities

Provide 4–6 concrete levers relevant to the jurisdictions that surfaced, such as:

  • Adopting or crediting a local QDMTT to keep top-up revenue in-country.
  • Increasing eligible substance (payroll/tangible assets) to grow the SBIE carve-out.
  • Reviewing deferred tax positions that affect adjusted covered taxes.
  • Applying the transitional CbCR safe harbours where thresholds are met.
  • Note the impact of the declining SBIE transition rates on future-year exposure. Flag any calculation driven by unadjusted proxy data as an estimate requiring GloBE-adjusted figures before filing.

Output Format

  • Structure: Assumptions block → per-jurisdiction ETR calculations → ranked exposure table → collection mechanism assignments → mitigation levers
  • Length: 800–1,200 words plus the exposure table
  • Format: Structured document with one summary table and short calculation walk-throughs per at-risk jurisdiction
  • Sections: Scope & Assumptions → GloBE ETR by Jurisdiction → Low-Tax Flags → SBIE Calculations → Top-up Tax by Jurisdiction → Collection Mechanism → Ranked Exposure Summary (table) → Mitigation Levers & Sensitivities
  • Tone: Technical tax advisory — precise, figures-first, conservative on assumptions, explicit about estimate vs. filing-grade calculation

Quality Checklist

Before delivering output, verify:

  • [ ] GloBE ETR is computed on a jurisdictional-blended basis, not entity-by-entity
  • [ ] Every jurisdiction is explicitly flagged above or below the 15% minimum
  • [ ] The SBIE uses the transition rate matching the stated fiscal year, and the rate is cited
  • [ ] Top-up tax is applied to excess profit (income net of SBIE), not gross GloBE income
  • [ ] Each residual exposure is assigned a collection mechanism (QDMTT / IIR / UTPR) and paying entity
  • [ ] The ranked table totals to a stated group-level exposure figure
  • [ ] Any output built on unadjusted proxy data is labeled an estimate, not a filing figure

Notes

  • QDMTT takes priority: where a low-tax jurisdiction has a qualified domestic top-up tax, residual IIR/UTPR liability generally falls to zero — check this before assuming parent-level exposure.
  • Jurisdictional blending means a single high-tax entity can pull a jurisdiction above 15% even if another entity there is low-taxed; always aggregate first.
  • The transitional CbCR safe harbours can exempt a jurisdiction from full calculation for early years — worth checking before running the full model if the group qualifies.
  • These are planning estimates. Filing-grade GloBE calculations require the full set of GloBE income and covered-tax adjustments, which should be confirmed with the group's tax advisors before submission.

How to use this skill

This file is a Claude Code skill in Anthropic's standard format — markdown with YAML frontmatter at the top.

Installing in Claude Code:

  • ~/.claude/skills/<folder-name>/SKILL.md — auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects)
  • <your-project>/.claude/skills/<folder-name>/SKILL.md — auto-loads only when working in that project (recommended for project-specific skills)

Restart Claude Code or open a new session to register.

Using in Claude.ai, ChatGPT, Gemini, or other AI tools:

  1. Drag this file into a new chat, or copy and paste its contents
  2. Send your task or request as your next message — the AI will apply the skill where it fits

For Claude Code skill details: https://docs.anthropic.com/en/docs/claude-code/skills