Undertaxed Profits Rule (UTPR)

Definition

UTPR acts as a backstop to IIR. When the parent jurisdiction has not adopted a qualified IIR, UTPR allocates top-up tax to other jurisdictions where the group has a presence based on the relative employees and tangible assets.

Examples

• A multinational headquartered in a non-Pillar Two jurisdiction faces UTPR collection in its operating jurisdictions.