Excluded Items
Excluded Entities: The following entities are excluded from the reporting obligation:
Governmental entities
International organizations
Non-profit organizations
Pension units
Investment vehicles that are ultimate parent entities
Real estate investment vehicles that are ultimate parent entities.
Conditional Exemptions: Entities may also be exempt from the reporting obligation if:
At least 95 percent of their shares are directly or indirectly held by one or more of the aforementioned excluded entities and they either primarily manage assets or invest funds for these entities or solely engage in ancillary activities.
Or if at least 85 percent of their shares are directly or indirectly held by one or more of the aforementioned excluded entities and they primarily generate profits or losses derived from the excluded entities.
Qualified Subsidiaries: A qualified subsidiary is also considered an excluded entity. It is defined as an entity whose entire equity shares are held by an excluded entity throughout the fiscal year, and whose revenues are less than 750 million euros and less than 25 percent of the consolidated revenues.
Deviation from Treatment: Upon request, a deviation from treatment as an excluded entity can be granted. The exercise of this option is subject to certain provisions under § 77 paragraph 2 of the law.
Tax Rates | |
CTR | Current Tax Rate |
DTR | Deferred Tax Rate |
Taxes on excluded items | |
EX-2.1 | Excluded Dividends – Article 3.2.1 (b) |
EX-2.2 | Current Tax Expense |
EX-2.3 | Deferred Tax Expense |
EX-3a.1 | Gains and losses from changes in fair value of an Ownership Interest (except for a Portfolio Shareholding); |
EX-3a.2 | Current Tax Expense |
EX-3a.3 | Deferred Tax Expense |
EX-3b.1 | Profit or loss in respect of an Ownership Interest that is included in Financial Accounting Net Income or Loss under the equity method of accounting; |
EX-3b.2 | Current Tax Expense |
EX-3b.3 | Deferred Tax Expense |
EX-3c.1 | Gains and losses from disposition of an Ownership Interest, except a Portfolio Shareholding |
EX-3c.2 | Current Tax Expense |
EX-3c.3 | Deferred Tax Expense |
EX-4.1 | Included Revaluation Method Gain or Loss – Article 3.2.1 (d) |
EX-4.2 | Current Tax Expense |
EX-4.3 | Deferred Tax Expense |
EX-5.1 | Gain or loss from disposition of assets and liabilities excluded under Article 6.3 – Article 3.2.1 € |
EX-5.2 | Current Tax Expense |
EX-5.3 | Deferred Tax Expense |
EX-6.1 | Asymmetric Foreign Currency Gains or Losses – Article 3.2.1 (f) |
EX-6.2 | Current Tax Expense |
EX-6.3 | Deferred Tax Expense |
EX-7.1 | Policy Disallowed Expenses – Article 3.2.1 (g) |
EX-7.2 | Current Tax Expense |
EX-7.3 | Deferred Tax Expense |
EX-8.1 | Prior Period Errors – Article 3.2.1 (h) |
EX-8.2 | Current Tax Expense |
EX-8.3 | Deferred Tax Expense |
EX-9.1 | Changes in Accounting Principles – Article 3.2.1(h) |
EX-9.2 | Current Tax Expense |
EX-9.3 | Deferred Tax Expense |
EX-10.1 | Accrued Pension Expense – Article 3.2.1 (i) |
EX-10.2 | Current Tax Expense |
EX-10.3 | Deferred Tax Expense |
EX-11.1 | Debt releases |
EX-11.2 | Current Tax Expense |
EX-11.3 | Deferred Tax Expense |
EX-12.1 | Adjustement related to the Stock-based compensation Election – Article 3.2.2 |
EX-12.2 | Current Tax Expense |
EX-12.3 | Deferred Tax Expense |
EX-13.1 | Arm’s length adjustments – Article 3.2.3 |
EX-13.2 | Current Tax Expense |
EX-13.3 | Deferred Tax Expense |
EX-15.1 | Election for Gains and losses using realisation principle – Article 3.2.5 |
EX-15.2 | Current Tax Expense |
EX-15.3 | Deferred Tax Expense |
EX-16.1 | Election for Adjusted Asset Gain – Article 3.2.6 |
EX-16.2 | Current Tax Expense |
EX-17.1 | Intragroup Financing Arrangement expense – Article 3.2.7 |
EX-17.2 | Current Tax Expense |
EX-17.3 | Deferred Tax Expense |
EX-18.1 | Election for intragroup transactions in same jurisdiction – Article 3.2.8 |
EX-18.2 | Current Tax Expense |
EX-18.3 | Deferred Tax Expense |
EX-19.1 | Insurance company taxes charged to policyholders – Article 3.2.9 |
EX-19.2 | Current Tax Expense |
EX-19.3 | Deferred Tax Expense |
EX-20.1 | Increase/decrease to equity attributed to Additional Tier One Capital distributions paid/payable or received/receivable – Article 3.2.10 |
EX-20.2 | Current Tax Expense |
EX-20.3 | Deferred Tax Expense |
EX-21.1 | Constituent Entities joining and leaving an MNE Group – Article 3.2.11 and 6.2 |
EX-21.2 | Current Tax Expense |
EX-21.3 | Deferred Tax Expense |
EX-22.1 | Reduction of GloBE Income of the UPE that is a Flow-through Entity – Article 3.2.11 and 7.1 |
EX-22.2 | Current Tax Expense |
EX-22.3 | Deferred Tax Expense |
EX-23.1 | Reduction of GloBE Income of the UPE that is subject to a Deductible Dividend Regime – Article 3.2.11 and 7.2 |
EX-23.2 | Current Tax Expense |
EX-23.3 | Deferred Tax Expense |
EX-24.1 | Taxable Distribution Method election – Article 3.2.11 and 7.6 |
EX-24.2 | Current Tax Expense |
EX-24.3 | Deferred Tax Expense |
EX-26.1 | Transactions between Constituent Entities |
EX-26.3 | Deferred Tax Expense |
EX-27.1 | Other Tax on excluded items |
EX-27.2 | Current Tax Expense |
EX-27.3 | Deferred Tax Expense |
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