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Excluded Items

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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.

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Conditional Exemptions: Entities may also be exempt from the reporting obligation if:

  1. 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.

  2. 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.

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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.

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The dialogue is to calculate or maintain the taxes on excluded items. The structure of the dialogue is as follows:

  1. Tax Rates
    At the top of the dialogue, it is possible to maintain a Current Tax Rate and Deferred Tax Rate. The tax rates can be imported and manually adjusted or completely manually inserted. For any calculations the total (sum of imported and manual value) percentage values are taken for the calculations.

  2. Taxes on excluded items
    In general there are three lines for each adjustment of the GloBE Income.
    The first line states the name of the GloBE Adjustment and with a click on transfer values you can see the adjustment that was made in the dialogue “GloBE Income”. It

There are different possibilities to

  • Calculate a suggestion for the taxes: The column “Amount excluded” for every adjustment of the GloBE Income states the value of the GloBE Adjustment in the first row, next to the amount of the

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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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