GloBE Rules Series

ITQ G-

153

January 30, 2026

Question

The UPE of an MNE Group is located in jurisdiction U, which has a Qualified SbS Regime. UPE is the only Constituent Entity located in jurisdiction U.

The group makes an election for the SbS Safe Harbour in its GIR. That GIR is shared with all countries where the group operates.

UPE owns 75% of the shares in HCo, which is located in jurisdiction H. The other 25% is owned by third parties. HCo is the only Constituent Entity located in jurisdiction H.

HCo owns 100% of the shares in XCo, which is located in jurisdiction X. XCo is the only Constituent Entity located in jurisdiction X.

HCo also owns 100% of the shares in YCo, which is located in jurisdiction Y. YCo is the only Constituent Entity located in jurisdiction Y.

Jurisdictions U and Y have not implemented either the GloBE rules or a QDMTT.

Jurisdictions H and X have each implemented the GloBE rules (IIR and UTPR) and a QDMTT.

Assume that in a fiscal year, the MNE Group has an amount of Top-up Tax in jurisdiction U, an amount of Top-up Tax in jurisdiction X, and an amount of Top-up Tax in jurisdiction Y.

Based on this limited information, which companies in the group will have tax liabilities under the GloBE rules and/or QDMTT?

Answer

Top-up Tax in jurisdiction X:

No IIR charge for HCo (POPE), due to SbS SH.

QDMTT charge imposed on XCo.

Top-up Tax in jurisdiction Y:

No IIR charge for HCo, due to SbS SH.

Top-up Tax in jurisdiction U:

No UTPR charge for HCo and XCo, due to Sbs SH.

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