Is your structure efficient —
or exposed to a top-up?
Model an indicative blended effective rate across your operating, holding, and IP jurisdictions, and see at a glance whether Pillar Two’s 15% global minimum tax is in scope, whether a top-up looks likely, and whether CFC attribution is a risk. A decision-support screen for CFOs and family offices — not a tax opinion.
Pillar Two applies at €750m+ in ≥2 of the last 4 years. This drives the scope flag.
Leave at zero to estimate from headline rates. Enter a figure to compute the accounting ETR directly.
Dataset version 2026-06-02. No data is sent or stored. Computation runs locally.
- The rate shown is an indicative accounting-style ETR — it is NOT the GloBE jurisdictional ETR, which uses covered taxes over GloBE income with specific adjustments and is computed per jurisdiction.
- The Substance-Based Income Exclusion (SBIE) — a carve-out for payroll and tangible assets — is NOT modelled here. Crypto groups typically hold little substance, so their real top-up can be HIGHER than a headline-rate comparison suggests.
- CFC, transfer-pricing, and substance analysis can change the outcome materially. This is a screen to decide whether to escalate, not a tax opinion.
- Bands are indicative and rounded. Validate every figure against group facts and financial-accounting treatment.
Indicative blend of the operating-jurisdiction headline rate and the lower-taxed holding / IP rate (a rough profit-allocation proxy — actual allocation can move this sharply).
- Operating jurisdiction: Cyprus — Headline CIT 15% (raised from 12.5% toward the Pillar Two floor). IP Box can take qualifying income to an effective ~2.5–3%.
- Holding / treasury jurisdiction: Cayman Islands — No corporate income tax. A 0% entity in an in-scope group is the textbook GloBE top-up and CFC-attribution case.
- Group revenue is below the €750m Pillar Two threshold, so the global minimum tax is not obviously in scope — but group-level testing over the last four years is still required to be sure.
- A low-tax holding or IP entity with high CFC sensitivity is present — profit parked there can be attributed back and taxed in the parent jurisdiction under CFC rules, independently of Pillar Two.
For orientation only — not financial, legal, regulatory, or investment advice. Outputs are directional and based on generalised inputs. Decisions should be taken only after consultation with a qualified adviser on your specific facts — book the full assessment before acting on anything you read here.
Numbers shown exclude finconduit fees and any third-party costs (legal, audit, regulator-mandated experts, banking-relationship fees, document-translation, ongoing supervisory levies, or local agent / service-provider charges). Real-world authorisation budgets typically exceed the headline regulator-side numbers by a meaningful multiple.