17/07/2025
XCo, a company located in jurisdiction X, is the UPE of an MNE Group which is "within scope" of the GloBE rules. Jurisdiction X has not implemented the GloBE rules.
XCo owns 100% of the shares in YCo 1, a company located in jurisdiction Y. XCo also owns 80% of the shares in YCo 2, another company located in jurisdiction Y. The remaining 20% of the shares in YCo 2 are owned by YCo 1. Jurisdiction Y has implemented the GloBE rules (IIR, UTPR, and QDMTT).
YCo 2 owns 90% of the shares in ZCo, a company located in jurisdiction Z. The other 10% of the shares in ZCo are owned by YCo 1. Jurisdiction Z has not implemented a QDMTT.
ZCo is the only Constituent Entity located in jurisdiction Z. 100 of top-up tax exists in regard to jurisdiction Z.
How much top-up tax will each of XCo, YCo 1, and YCo 2 be required to pay?
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