Pillar Two sets a global minimum effective tax rate of fifteen per cent for large groups, collected through a system of top-up taxes.
Why it matters
A sub-fifteen-per-cent effective rate now invites a top-up that collects the difference. This briefing focuses on in-scope groups: the revenue threshold — how the consolidated-revenue threshold determines which groups fall within the global minimum tax.
In practice
The computation recasts accounting income and covered taxes into a GloBE effective rate by jurisdiction, applies the substance carve-out, and tops up any shortfall to the floor.
- A sub-floor effective rate triggers a top-up to fifteen per cent.
- Rate-based incentives lose value for in-scope groups.
- Build the GloBE data pipeline early.
This is a short briefing note. For the full treatment of this programme, see the AG6 Tax & Treaty working papers.
Suggested citation: AG6 Research (2026), In-Scope Groups: The Revenue Threshold, CBX-04 · BN-001, Cross-Border Research Centre, a Silversix Consultant & Silversix Labs initiative.
Law considered as at December 2025. This article is research and educational commentary on a cross-border framework that develops through legislation, guidance and case law; rates, thresholds, forms and dates change and turn on specific facts. It is not legal, tax or regulatory advice and must not be relied on for any transaction. Verify every figure and rule against current primary sources and obtain advice from a qualified professional before acting.