MTT09950 - Reference materials: Table of abbreviations and acronyms
This page provides a list of abbreviations and acronyms that may be encountered when working on Pillar Two.
The list is intended as a convenient reference aid only. For definitions and explanations of defined terms, please use the search function in the manual.
|
Abbreviation / acronym |
Meaning |
|---|---|
|
AG / AAG |
Administrative Guidance / Agreed Administrative Guidance |
|
AFXGL |
Asymmetric Foreign Exchange Currency Gain or Loss |
|
AT1 |
Additional Tier 1 (Capital) |
|
ATL |
Above the Line |
|
BCAA |
Bilateral Competent Authority Agreement |
|
BEPS |
Base Erosion and Profit Shifting |
|
BTA |
Business Tax Account |
|
BTL |
Below the Line (e.g. tax refund) |
|
BTN |
Below Threshold Notification |
|
CbC / CbCR |
Country-by-Country / Country-by-Country Reporting |
|
CE |
Constituent Entity (equivalent to "member" in UK legislation) |
|
CFC |
Controlled Foreign Company |
|
CFS |
Consolidated Financial Statements |
|
CIT |
Corporate Income Tax |
|
DIIR |
Domestic Income Inclusion Rule (a specific type of IIR, see MTT62410) |
DMT / DMTT |
Domestic Minimum Top-up Tax (usually QDMTT, when qualifying under the peer review process) |
|
DTA |
Deferred Tax Accounting Deferred Tax Asset |
|
DTL |
Deferred Tax Liability |
|
DTT |
Domestic Top-up Tax (the UK implementation of QDMTT) |
|
ETA |
Eligible Tangible Assets |
|
ETR |
Effective Tax Rate |
|
FANIL |
Financial Accounting Net Income or Loss (equivalent to "underlying profits" in UK legislation) |
|
FTC |
Foreign Tax Credit |
|
FTE |
Flow-Through Entity |
|
GILTI |
Global Intangible Low-Taxed Income (now NCTI) |
|
GIR |
GloBE Information Return |
|
GIR MCAA |
Multilateral Competent Authority Agreement on the Exchange of GloBE Information |
|
GloBE |
Global Anti-Base Erosion - may be used to refer to the main ruleset in the Model Rules (i.e. IIR and UTPR), distinguished with either a QDMTT or one or more of the Safe Harbour rulesets |
|
GMT |
Global Minimum Tax |
|
IF |
OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting. The Inclusive Framework expands the OECD countries to include others who intend to implement Pillar Two. |
|
IFRS |
International Financial Reporting Standards |
|
IIR |
Income Inclusion Rule |
|
JITE |
Jurisdictional Income Tax Expense |
|
JPBT |
Jurisdictional Profit (or Loss) before Income Tax |
|
JV |
Joint Venture (defined specifically for Pillar Two purposes) |
|
LFAS |
Local Financial Accounting Standard (an alternative basis for calculations using local GAAP available in some QDMTTs) |
|
LTCE |
Low-Taxed Constituent Entity (i.e. a member in a territory where the ETR is less than 15%) |
|
M&A |
Mergers and Acquisitions |
|
M2M |
Mark to Market |
|
MAAC |
Multilateral Convention on Mutual Administrative Assistance in Tax Matters |
|
MCAA |
Multilateral Competent Authority Agreement |
|
MNE |
Multinational Enterprise (referred to as "multinational group" in UK legislation) |
|
MOCE |
Minority-Owned Constituent Entity |
|
MR |
Model Rules |
|
MTTC |
Marketable Transferable Tax Credit |
|
MTT |
Multinational Top-up Tax (UK implementation of the IIR and UTPR) |
|
NCTI |
Net CFC Tested Income (previously GILTI) |
|
NMCE |
Non-Material Constituent Entity |
|
NMTC |
Non-Marketable Transferable Tax Credit |
|
OCI |
Other Comprehensive Income |
|
OECD |
Organisation for Economic Co-operation and Development |
|
ORIP |
Offshore Receipts in respect of Intellectual Property |
|
ORN |
Overseas Return Notification |
|
PE |
Permanent Establishment |
|
POPE |
Partially-Owned Parent Entity |
|
PPA |
Purchase Price Accounting/Adjustments/Allocation |
|
QDMTT |
Qualifying Domestic Minimum Top-up Tax |
|
QDT credit |
Qualifying Domestic Top-up Tax Credit |
QIIR |
Qualifying Income Inclusion Rule |
|
QRTC |
Qualifying Refundable Tax Credit |
|
QTI |
Qualifying Tax Incentive |
|
QUTPR |
Qualifying Undertaxed Profits Rule |
|
RDEC |
Research and Development Expenditure Credit |
|
REA |
Recapture Exception Accrual |
|
REIT / REIV |
Real Estate Investment Trust / Real Estate Investment Vehicle |
|
RT1 |
Restricted Tier 1 (Capital) |
|
SBIE |
Substance-Based Income Exclusion |
|
SBTI |
Substance-Based Tax Incentive (Safe Harbour) |
|
SbS |
Side-by-Side (Safe Harbour) |
|
SESH |
Simplified ETR Safe Harbour |
|
SH |
Safe Harbour |
|
STTR |
Subject-To-Tax Rule |
|
TCSH |
Transitional CbCR Safe Harbour |
|
TP |
Transfer Pricing Top-up Tax (uncommon) |
|
TPR |
Transitional Penalty Relief (in some guidance) |
|
TSH |
Transitional Safe Harbour (the CbCR Safe Harbour) |
|
TTC |
Transferable Tax Credit |
|
UPE |
Ultimate Parent Entity |
|
UTPR |
The backstop rule to the Income Inclusion Rule, generally referred to as the Undertaxed Profits Rule although it has no official title in OECD documents |