Clarification on Top-Up Tax Calculation Logic in TRCS
As per the TRCS Admin Guide, the logic for calculating top-up tax is based on entity-level ETR. It states that if an entity’s ETR is below the Pillar Two tax rate (15%), then top-up tax must be calculated.
However, according to the OECD Pillar Two guidelines, the requirement is different. Top-up tax should only be calculated if a jurisdiction’s ETR is below the Pillar Two tax rate (15%), and this calculation should be based on jurisdictional profits, not entity-level ETR.
This appears to be a discrepancy between TRCS implementation and OECD guidance.
Could you please confirm:
Is TRCS designed to calculate top-up tax at the entity level or jurisdiction level?