SolvedMTT09950 | Reference materials: Table of abbreviations and acronyms
From HM Revenue & Customs · Multinational Top-up Tax and Domestic Top-up Tax
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 AccountingDeferred 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 PricingTop-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 |