Searching for Pillar Two clarity: The OECD’s Administrative Guidance
Cross-border Tax Talks
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The Qualified Domestic Minimum Top-Up Tax
The QDMTT is a qualified domestic minimum top-up tax. It's meant to be calculated based upon the domestic excess profit. The general thought is computed just like you would in an IR or UTPR, I'll be at U Apply it at the domestic level. But they acknowledge that there are going to be certain differences in how that assessment will be made and that within itself will not disqualify it from being a Qualified Domestic Minimum Top Up Tax.
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