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.
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CTR
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Current Tax Rate
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DTR
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Deferred Tax Rate
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EX-2.1
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Excluded Dividends – Article 3.2.1 (b)
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EX-2.2
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Current Tax Expense
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EX-2.3
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Deferred Tax Expense
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EX-3a.1
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Gains and losses from changes in fair value of an Ownership Interest (except for a Portfolio Shareholding);
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EX-3a.2
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Current Tax Expense
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EX-3a.3
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Deferred Tax Expense
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EX-3b.1
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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;
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EX-3b.2
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Current Tax Expense
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EX-3b.3
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Deferred Tax Expense
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EX-3c.1
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Gains and losses from disposition of an Ownership Interest, except a Portfolio Shareholding
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EX-3c.2
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Current Tax Expense
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EX-3c.3
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Deferred Tax Expense
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EX-4.1
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Included Revaluation Method Gain or Loss – Article 3.2.1 (d)
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EX-4.2
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Current Tax Expense
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EX-4.3
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Deferred Tax Expense
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EX-5.1
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Gain or loss from disposition of assets and liabilities excluded under Article 6.3 – Article 3.2.1 €
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EX-5.2
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Current Tax Expense
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EX-5.3
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Deferred Tax Expense
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EX-6.1
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Asymmetric Foreign Currency Gains or Losses – Article 3.2.1 (f)
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EX-6.2
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Current Tax Expense
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EX-6.3
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Deferred Tax Expense
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EX-7.1
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Policy Disallowed Expenses – Article 3.2.1 (g)
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EX-7.2
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Current Tax Expense
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EX-7.3
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Deferred Tax Expense
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EX-8.1
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Prior Period Errors – Article 3.2.1 (h)
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EX-8.2
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Current Tax Expense
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EX-8.3
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Deferred Tax Expense
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EX-9.1
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Changes in Accounting Principles – Article 3.2.1(h)
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EX-9.2
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Current Tax Expense
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EX-9.3
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Deferred Tax Expense
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EX-10.1
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Accrued Pension Expense – Article 3.2.1 (i)
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EX-10.2
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Current Tax Expense
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EX-10.3
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Deferred Tax Expense
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EX-11.1
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Debt releases
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EX-11.2
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Current Tax Expense
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EX-11.3
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Deferred Tax Expense
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EX-12.1
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Adjustement related to the Stock-based compensation Election – Article 3.2.2
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EX-12.2
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Current Tax Expense
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EX-12.3
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Deferred Tax Expense
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EX-13.1
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Arm’s length adjustments – Article 3.2.3
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EX-13.2
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Current Tax Expense
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EX-13.3
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Deferred Tax Expense
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EX-15.1
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Election for Gains and losses using realisation principle – Article 3.2.5
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EX-15.2
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Current Tax Expense
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EX-15.3
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Deferred Tax Expense
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EX-16.1
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Election for Adjusted Asset Gain – Article 3.2.6
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EX-16.2
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Current Tax Expense
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EX-17.1
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Intragroup Financing Arrangement expense – Article 3.2.7
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EX-17.2
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Current Tax Expense
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EX-17.3
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Deferred Tax Expense
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EX-18.1
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Election for intragroup transactions in same jurisdiction – Article 3.2.8
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EX-18.2
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Current Tax Expense
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EX-18.3
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Deferred Tax Expense
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EX-19.1
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Insurance company taxes charged to policyholders – Article 3.2.9
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EX-19.2
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Current Tax Expense
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EX-19.3
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Deferred Tax Expense
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EX-20.1
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Increase/decrease to equity attributed to Additional Tier One Capital distributions paid/payable or received/receivable – Article 3.2.10
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EX-20.2
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Current Tax Expense
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EX-20.3
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Deferred Tax Expense
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EX-21.1
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Constituent Entities joining and leaving an MNE Group – Article 3.2.11 and 6.2
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EX-21.2
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Current Tax Expense
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EX-21.3
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Deferred Tax Expense
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EX-22.1
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Reduction of GloBE Income of the UPE that is a Flow-through Entity – Article 3.2.11 and 7.1
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EX-22.2
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Current Tax Expense
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EX-22.3
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Deferred Tax Expense
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EX-23.1
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Reduction of GloBE Income of the UPE that is subject to a Deductible Dividend Regime – Article 3.2.11 and 7.2
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EX-23.2
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Current Tax Expense
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EX-23.3
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Deferred Tax Expense
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EX-24.1
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Taxable Distribution Method election – Article 3.2.11 and 7.6
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EX-24.2
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Current Tax Expense
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EX-24.3
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Deferred Tax Expense
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EX-26.1
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Transactions between Constituent Entities
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EX-26.3
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Deferred Tax Expense
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EX-27.1
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Other Tax on excluded items
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EX-27.2
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Current Tax Expense
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EX-27.3
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The dialogue is to calculate or maintain the taxes on excluded items. The structure of the dialogue is as follows:
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.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”. This value is not part of any calculation, but to visualize the Total Amount of the adjustment. In the first line it is also possible to add additional information for the taxes on excluded items such as files or comments.
The second line is the line for current taxes on this adjustment. If the excluded item comes with an adjustment in the current taxes, this is done in this row. For the different possiblities to insert the current taxes please read the section below.
The third line is the line for deferred taxes on this adjustment. If the excluded item comes with an adjustment in the deferred taxes, this is done in this row. For the different possiblities to insert the current taxes please read the section below.
Some Adjustment come with an adjustment that only affects either the current taxes or the deferred taxes. These Adjustments also don’t add up to the sum for the general taxes on excluded items but have a special line in the Global Information Return and therefore also in the Calculation.
There are different possibilities to calculate or insert the taxes linked to the adjustment:
Calculate a suggestion for the tax expense
To calculate a suggestion, an amount excluded has to be inserted in the first column by import. Depending on if the excluded item comes with an adjustment in current tax expense or deferred tax expense, the tax base has to be imported in the first column. The second column then calculates a suggestion with the respective tax rate. It is possible to adjust this suggestion by import (third row) or manually (fourth row).
Three examples:In the easiest case, the Adjustment affects either the current tax expense or the deferred tax expense and there are no tax-free amounts. Then the Amount excluded states the same value as the complete adjustment in the first row. The second column then calculates “Amount excluded times the respective tax rate” and states the result as the suggestion for the tax that needs to be excluded. The amount can be imported from external sources (csv, data transfer) or internal the total amount of the adjustment of the GloBE Income (Transfer Values Mapping).
It is also possible, that the adjustment affects both current tax expense and the deferred tax expense. In that case, the tax base needs to be imported from external sources since the user has to decide which share of the amount affected the current tax expense and which share affected the deferred tax expense.
In case of tax-free amounts, it is possible, that the amount, or part of the amount excluded does neither affect the current tax expense, nor the deferred tax expense. In this case also an import from external sources (csv, data transfer) is necessary for the amount excluded. The sum of the amounts in the second and third rows won’t add up to the complete amount excluded in the first row in this case.
Import or manual statement of the tax expense that needs to be corrected
It is possible to not import into the first column of the Dialogue. In that case, the Tax Rates don’t need to be filled, and the suggestion stays zero. The amount of tax expense can directly be imported to the third row or manually inserted or adjusted in the fourth row.It is possible to deviate between the possibilities
For some adjustments the deferred tax expense may be available in the GTC or in the pre-system and therefore immediately mapped to the tax expense. Some adjustments may need to be calculated because there are no information about the tax expense that was connected to this adjustment. It is possible to decide for each adjustment which possibility is the most efficient way to get the tax expense that needs to be corrected.
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International Shipping
In this dialogue the relevant information to calculate the adjustments in regard to International Shipping is collected. At the current stage it is not connected to the Calculations.
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