C1 - Safe Harbour Check
The Safe Harbour Check gives an overview about the aggregated values from the dialogues CbCR Safe Harbour and Substance-based Income Exclusion. The calculation includes the three tests “Simplified ETR Test” (1), “De Minimis Test” (2) and the “Routine Profits Test” (3). The Calculation is completed with additional information about the general applicability e.g. because the transitional Safe Harbour is available in the year (4) and if the election wasn’t already evoked in a prior fiscal year (5). The result of all information is the applicability of the CbCR Safe Harbour (6).
The Aggregation is performed with the Reporting Dimension Type selected for the CbCR-Safe Harbour Blending. For more information on Reporting Dimension Types please see the section on Administration.
Simplified ETR Test | |
1.1 | Qualified CbCR Profit (Loss) before Income Tax States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-2. |
1.3 | Income Tax Expense (including uncertain tax positions) States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-3.1. |
1.4 | Income Tax Expense related to uncertain tax positions States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-3.2. |
1.5 | Income Tax Expense (after eliminating uncertain tax positions) States the Income Tax Expense after eliminating uncertain tax positions, the calculation is as follows, {1.3} - {1.4} |
1.6 | Simplified ETR States the Simplified ETR by dividing the Income Tax (1.5) with the Qualified CbCR Profit (Loss) before Income Tax, the calculation is as follows, {1.5} / {1.1} * 100 |
1.7 | Transition Rate States the fixed Transition Rate of 15%. |
1.8 | Simplified ETR Test successful? The Simplified ETR Test is successful if either the Simplified ETR is smaller or equal to the Transition Rate or in case of a Qualified CbCR Loss and positive Income Tax Expense. {1.7} <= {1.6} {1.1} <= 0 & {1.5} >= 0 |
De Minimis Test | |
2.1 | Qualified CbCR Revenue States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-1. |
2.3 | Average GloBE Revenue threshold States the fixed GloBE Revenue threshold of 10’000’000. |
2.4 | Qualified CbCR Profit (Loss) before Income Tax States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-2. |
2.6 | Average GloBE Income threshold States the fixed GloBE Income threshold of 1’000’000. |
2.7 | De Minimis Test successful? The De Minimis Test is successful, if both, the aggregated Qualified CbCR Revenue and the aggregated Qualified CbCR Profit (Loss) are below the GloBE thresholds. {2.1} < {2.3} & {2.5} < {2.6} |
Routine Profits Test | |
3.1 | Qualified CbCR Profit (Loss) before Income Tax States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CbCR-2. |
3.2 | Relevant Eligible Payroll Costs of Eligible Employees performing activities in the jurisdiction States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CO-1.1. |
3.3 | Application of relevant mark-up percentage for the Reporting Fiscal Year Currently fixed at 9,8 % for 2024. Will vary with the year in which the Reporting Fiscal year starts after the next update. |
3.4 | Payroll Carve-Out Amount States for each entity the Amount of Eligible Payroll Costs multiplied by the relevant mark-up percentage, the calculation is as follows: {3.2} * {3.3} |
3.5a | Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the beginning of the reporting year States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CO-2.1. |
3.5b | Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the end of the reporting year States for each jurisdiction or subgroup the aggregate of the “Total” value of the entity data collection in CO-2.2. |
3.5 | Carrying value of relevant Eligible Tangible Assets located in the jurisdiction States for each jurisdiction or subgroup the arithmetic mean of the Carrying value of Eligible Tangible Assets at the beginning of the reporting year and the end of the reporting year, the calculation is as follows: ({3.5a} + {3.5b}) / 2 |
3.6 | Application of relevant mark-up percentage for the Reporting Fiscal Year Currently fixed at 7,8 % for 2024. Will vary with the year in which the Reporting Fiscal year starts after the next update. |
3.7 | Tangible Assets Carve-Out Amount States for each jurisdiction or subgroup the Carrying value of relevant Eligible Tangible Assets multiplied by the relevant mark-up percentage, the calculation is as follows: {3.2} * {3.3} |
3.8 | Total amount of the Substance Based Income Exclusion States for each jurisdiction or subgroup the sum of the Payroll Carve-Out Amount and the Tangible Assets Carve-Out Amount, the calculation is as follows: {3.4} + {3.7} |
3.9 | Routine Profits Test successful? The Routine Profits Test is successful, if the Total amount of the Substance Based Income Exclusion is below the Qualified CbCR Profit (Loss). {3.8} < {3.1} |
Overall Applicability | |
4 | Transitional CbCR Safe Harbour available for the Fiscal Year? |
5 | Election to use Transitional CbCR Safe Harbour in the last Fiscal Year? |
6 | Transitional CbCR Safe Harbour applicable for the Fiscal Year? Transitional CbCR Safe Harbour is applicable, if one of the three tests (1.8), (2.7) or (3.9) is successful as well as the general applicability is given because the CbCR Safe Harbour is available in the Fiscal Year (4) and the election wasn’t already evoked in an earlier year. (5) |