Charging Provisions

<< Go back to overview Next article>> Article 2.5 UTPR Top-up Tax Amount Article 2.5 provides the methodology to determine the amount of Top-up Tax that is allocated to the UTPR Jurisdiction under the UTPR. The Total UTPR Top-up Tax Amount is determined by reference to the total amount [...]

<< Go back to overview Next article>> Article 2.4 Application of the UTPR The UTPR provides a mechanism for making an adjustment in respect of the Top-up Tax that is calculated for an LTCE to the extent that such Top-up Tax is not brought within the charge of a [...]

<< Go back to overview Next article>> Article 2.3 IIR Offset Mechanism Article 2.3. IIR Offset Mechanism 2.3.1 A Parent Entity that owns an Ownership Interest in a Low-Taxed Constituent Entity indirectly through an Intermediate Parent Entity or a Partially-Owned Parent Entity that is not eligible for an exclusion [...]

<< Go back to overview Next article>> Article 2.2 Allocation of Top-Up Tax under the IIR Entities subject to the IIR pay tax in an amount equal to their “Allocable Share” of Top-up Tax. Article 2.2 contains the rules for the attribution of Top-up Tax under this rule. Article [...]

Article 2.1 Application of the IIR Article 2.1 identifies the Entities in the MNE Group that are required to apply the rule. The IIR is applied by a Parent Entity, which under the definition in Article 10.1, can be a UPE that is not an Excluded Entity, or an Intermediate Parent Entity, or [...]