T473 · Tax / GloBE · AINumbers.co

GloBE ETR Jurisdiction Calculator

OECD Pillar Two Global Minimum Tax: GloBE Effective Tax Rate (ETR) per jurisdiction. GloBE ETR = Adjusted Covered Taxes ÷ GloBE Income per OECD GloBE Model Rules Art. 5.1.1. Minimum rate: 15%. Substance-based income exclusion (SBIE): 5% × qualifying payroll + 5% × qualifying tangible assets (transitional rates 2024–2032 per Art. 5.3). Jurisdictions below 15% ETR are subject to top-up tax (computed in T474).

OECD Pillar Two GloBE 15% minimum ETR SBIE · Art. 5.3 US-HQ groups: IIR/UTPR exemption applies (Jan 2026) Deterministic · Zero PII · Client-side

⚠ US Headquarter Exemption: As of January 2026, US-headquartered MNE groups are exempt from IIR and UTPR under the OECD "side-by-side" package (US Treasury announcement, January 2026). The top-up tax computed by this tool and T474 applies to non-US-parented groups and to QDMTT exposure for all groups (including US-parented) in GloBE-implementing jurisdictions. Do not apply IIR/UTPR to US-HQ groups. Verify current US position at oecd.org.

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GloBE inputs per jurisdiction

Enter GloBE income, covered taxes, qualifying payroll, and tangible assets per constituent entity group in each jurisdiction. GloBE income net of SBIE is the base for top-up tax computation (T474). All amounts in the same reporting currency.

Jurisdiction (ISO)	GloBE income (m)	Covered taxes (m)	Payroll (m)	Tangible assets (m)	SBIE rate %

GloBE ETR Results

Sources: OECD GloBE Model Rules (released December 2021); OECD Commentary (March 2022); OECD Administrative Guidance (February 2023, July 2023, December 2023, June 2024). SBIE transitional rates: Art. 9.1 / Agreed Administrative Guidance. Minimum rate: 15% (Art. 5.2.4). ⚠ Verify SBIE rates and covered-tax adjustments against current OECD guidance and local implementing legislation. US exemption: OECD side-by-side package (January 2026). GIR first filings: 30 June 2026 for FY2024 groups.