The Top-Up Tax Allocation shows the allocation of the Top-Up Tax Amount per Jurisdiction or Subgroup to the low-taxed CEs with a positive GloBE Income. By multiplying the allocated Top-Up Tax with the Inclusion Ratio of each CE, the Top-Up Tax Expense of the separate low-taxed CE or member of Joint Venture Group is calculated. The Information of the Inclusion Ratio is taken from the Entity Data Collection and more specific from the dialogue “Top-Up Tax Allocation”.
Low-taxed CE allocated Top-Up Tax | |
|---|---|
GROUPNAME | Jurisdiction or Subgroup |
TA-2.1 | Positive GloBE Income of the low-taxed CE or member of Joint Venture Group |
TA-2.2 | Total GloBE Income of the Jurisdiction or Subgroup States the sum of positive GloBE Income {INC-3} of the whole corresponding Jurisdiction or Subgroup. |
TA-2 | Relevant Percentage of the Net GloBE Income States the share of the positive GloBE Income of each CE in percentage, the calculation is as follows, {TA-2.1} / {TA-2.2} * 100 |
TA-3.1 | Total Top-Up Tax Amount of the Jurisdiction or Subgroup States the total amount of Top-Up Tax of the Jurisdictional Blending {TT-3}. |
TA-3 | Top-Up Tax Amount of the low-taxed CE or member of Joint Venture Group States the Top-Up Tax amount allocated to the respective CE, the calculation is as follows, {TA-2} * {TA-3.1} / 100 |
Income Inclusion Rule | |
TA-4.1 | Inclusion Ratio States for each entity the “Total” percentage of the entity data collection in IR-1. |
TA-4.2 | Top-Up Tax Expense of the low-taxed CE or member of Joint Venture Group States for each entity the Top-Up Tax Expense in regard to the inclusion ratio, the calculation is as follows, {TA-3} * {TA-4.1} / 100 |