Pillar II’s arsenals to enforce minimum tax of 15%

Pillar II’s arsenals to enforce minimum tax of 15%

Fact: Regulations for topping up taxes must be implemented in a specific sequence by adjusting the qualified domestic minimum top-up tax (QDMTT), followed by the treaty-based subject to tax rule (STTR), the income inclusion rule (IIR), and finally, the under-tax payment rule (UTPR).