C4 - Jurisdictional Blending
The Jurisdictional Blending gives an overview about the values aggregated on a per jurisdiction or per subgroup level to calculate the Top-Up Tax. The first part of the calculation shows the jurisdictional elections per jurisdiction. The second part of the calculation shows the aggregated values of the GloBE Income, the Adjusted Covered Taxes and the Substance-based Income Exclusion. For the calculation of the Adjusted Covered Taxes here also a possible GloBE Loss Carry-Forward and Excess Negative Tax Carry-Forward are considered. The aggregated values are used to calculate the Top-Up Tax of the Jurisdiction or Subgroup and the calculation ends with informational values regarding a GloBE Loss Carry-Forward, an Excess Negative Tax Carry-Forward and Aggregate Asset Gains.
The Aggregation is performed with the Reporting Dimension Type selected for the Top-Up Tax Blending. For more information on Reporting Dimension Types please see the section on Administration.
| Determination of Net GloBE Income (Loss) |
INC-1 | Aggregate Financial Accounting Net Income or Loss amount after allocations in Articles 3.4 and 3.5 Aggregates the values of INC-1 of the respective jurisdiction or subgroup. |
INC-2.1 | Net Taxes Expense - Article 3.2.1 (a) Aggregates the values of INC-2.1 of the respective jurisdiction or subgroup. |
INC-2.2 | Excluded Dividends – Article 3.2.1 (b) Aggregates the values of INC-2.2 of the respective jurisdiction or subgroup. |
INC-2.3 | Excluded Equity Gain or Loss – Article 3.2.1 (c) Aggregates the values of INC-2.3 of the respective jurisdiction or subgroup. |
INC-2.4 | Included Revaluation Method Gain or Loss – Article 3.2.1 (d) Aggregates the values of INC-2.4 of the respective jurisdiction or subgroup. |
INC-2.5 | Gain or loss from disposition of assets and liabilities excluded under Article 6.3 – Article 3.2.1 (e) Aggregates the values of INC-2.5 of the respective jurisdiction or subgroup. |
INC-2.6 | Asymmetric Foreign Currency Gains or Losses – Article 3.2.1 (f) Aggregates the values of INC-2.6 of the respective jurisdiction or subgroup. |
INC-2.7 | Policy Disallowed Expenses – Article 3.2.1 (g) Aggregates the values of INC-2.7 of the respective jurisdiction or subgroup. |
INC-2.8 | Prior Period Errors – Article 3.2.1 (h) Aggregates the values of INC-2.8 of the respective jurisdiction or subgroup. |
INC-2.9 | Changes in Accounting Principles – Article 3.2.1(h) Aggregates the values of INC-2.9 of the respective jurisdiction or subgroup. |
INC-2.10 | Accrued Pension Expense – Article 3.2.1 (i) Aggregates the values of INC-2.10 of the respective jurisdiction or subgroup. |
INC-2.11 | Debt releases - Article 3.2.1 Aggregates the values of INC-2.11 of the respective jurisdiction or subgroup. |
INC-2.12 | Stock-based compensation – Article 3.2.2 Aggregates the values of INC-2.12 of the respective jurisdiction or subgroup. |
INC-2.13 | Arm’s length adjustments – Article 3.2.3 Aggregates the values of INC-2.13 of the respective jurisdiction or subgroup. |
INC-2.14 | Qualified Refundable Tax Credit – Article 3.2.4 Aggregates the values of INC-2.14 of the respective jurisdiction or subgroup. |
INC-2.15 | Election for Gains and losses using realisation principle – Article 3.2.5 Aggregates the values of INC-2.15 of the respective jurisdiction or subgroup. |
INC-2.16 | Election for Adjusted Asset Gain – Article 3.2.6 Aggregates the values of INC-2.16 of the respective jurisdiction or subgroup. |
INC-2.17 | Intragroup Financing Arrangement expense – Article 3.2.7 Aggregates the values of INC-2.17 of the respective jurisdiction or subgroup. |
INC-2.18 | Election for intragroup transactions in same jurisdiction – Article 3.2.8 Aggregates the values of INC-2.18 of the respective jurisdiction or subgroup. |
INC-2.19 | Insurance company taxes charged to policyholders – Article 3.2.9 Aggregates the values of INC-2.19 of the respective jurisdiction or subgroup. |
INC-2.20 | Increase/decrease to equity attributed to Additional Tier One Capital distributions paid/payable or received/receivable – Article 3.2.10. Aggregates the values of INC-2.20 of the respective jurisdiction or subgroup. |
INC-2.21 | Constituent Entities joining and leaving an MNE Group – Article 3.2.11 and 6.2. Aggregates the values of INC-2.21 of the respective jurisdiction or subgroup. |
INC-2.22 | Reduction of GloBE Income of the UPE that is a Flow-through Entity – Article 3.2.11 and 7.1. Aggregates the values of INC-2.22 of the respective jurisdiction or subgroup. |
INC-2.23 | Reduction of GloBE Income of the UPE that is subject to a Deductible Dividend Regime – Article 3.2.11 and 7.2. Aggregates the values of INC-2.23 of the respective jurisdiction or subgroup. |
INC-2.24 | Taxable Distribution Method election – Article 3.2.11 and 7.6 Aggregates the values of INC-2.24 of the respective jurisdiction or subgroup. |
INC-2.25 | International Shipping Income – Article 3.3 Aggregates the values of INC-2.25 of the respective jurisdiction or subgroup. |
INC-2.26 | Transactions between Constituent Entities - Article 9.1.3 Aggregates the values of INC-2.26 of the respective jurisdiction or subgroup. |
INC-2 | Sum of Adjustments Aggregates the values of INC-2 of the respective jurisdiction or subgroup. |
INC-3 | Net GloBE Income (Loss) Aggregates the values of INC-3 of the respective jurisdiction or subgroup. |
| Determination of Covered Current Taxes |
CT-1 | Current tax expense with respect to Covered Taxes after allocations in Article 4.3 Aggregates the values of CT-1 of the respective jurisdiction or subgroup. |
CT-2.1 | Covered Tax accrued as an expense in the profit before taxation in the financial accounts - Article 4.1.2 (a) Aggregates the values of CT-2.1 of the respective jurisdiction or subgroup. |
CT-2.2 | GloBE Loss Deferred Tax Asset established under Article 4.5.1 or used – Article 4.1.2 (b) combined with Article 4.5.3 Aggregates the values of CT-2.2 of the respective jurisdiction or subgroup. |
CT-2.3 | Covered Taxes for uncertain tax position recorded as a reduction to Covered Taxes in prior year – Article 4.1.2 (c) Aggregates the values of CT-2.3 of the respective jurisdiction or subgroup. |
CT-2.4 | Qualified Refundable Tax Credit recorded as a reduction to current tax expense – Article 4.1.2 (d) Aggregates the values of CT-2.4 of the respective jurisdiction or subgroup. |
CT-2.5 | Qualified Flow-through Tax Benefits of Qualified Ownership Interests - Article 3.2.1 (c) Aggregates the values of CT-2.5 of the respective jurisdiction or subgroup. |
CT-2.6 | Current tax expense on income excluded from GloBE Income or Loss – Article 4.1.3 (a) Aggregates the values of CT-2.6 of the respective jurisdiction or subgroup. |
CT-2.7 | Non-Qualified Refundable Tax Credit not recorded as a reduction to current tax expense – Article 4.1.3 (b) Aggregates the values of CT-2.7 of the respective jurisdiction or subgroup. |
CT-2.8 | Covered Taxes refunded or credited (except for any Qualified Refundable Tax Credit) not treated as an adjustment to current tax expense – Article 4.1.3 (c) Aggregates the values of CT-2.8 of the respective jurisdiction or subgroup. |
CT-2.9 | Current tax expense related to uncertain tax position– Article 4.1.3 (d) Aggregates the values of CT-2.9 of the respective jurisdiction or subgroup. |
CT-2.10 | Current tax expense not expected to be paid within three years – Article 4.1.3 (e) Aggregates the values of CT-2.10 of the respective jurisdiction or subgroup. |
CT-2.11 | Post-filing adjustments – Article 4.6.1 Aggregates the values of CT-2.11 of the respective jurisdiction or subgroup. |
CT-2.12 | Covered Taxes relating to Net Asset Gain or Net Asset Loss – Article 3.2.6 Aggregates the values of CT-2.12 of the respective jurisdiction or subgroup. |
CT-2.13 | Reduction of Covered Taxes of the UPE that is a Flow-through Entity – Article 7.1 Aggregates the values of CT-2.13 of the respective jurisdiction or subgroup. |
CT-2.14 | Covered Taxes for GloBE Income of the UPE that is reduced under a Deductible Dividend Regime – Article 7.2.2 Aggregates the values of CT-2.14 of the respective jurisdiction or subgroup. |
CT-2.15 | Deemed Distribution Tax– Article 7.3 Aggregates the values of CT-2.15 of the respective jurisdiction or subgroup. |
CT-2.16 | Taxable Distribution Method election – Article 7.6 Aggregates the values of CT-2.16 of the respective jurisdiction or subgroup. |
CT-2 | Sum of Adjustments Aggregates the values of CT-2 of the respective jurisdiction or subgroup. |
CT-3 | Current Taxes after Adjustments Aggregates the values of CT-3 of the respective jurisdiction or subgroup. |
CT-4 | Increase or decrease in Covered Taxes recorded in equity or Other Comprehensive Income relating to amounts included in GloBE Income or Loss that will be subject to tax under local tax rules – Article 4.1.1 (c) Aggregates the values of CT-4 of the respective jurisdiction or subgroup. |
| Determination of Covered Deferred Taxes |
DT-1 | Deferred tax expense amount Aggregates the values of DT-1 of the respective jurisdiction or subgroup. |
DT-2.1 | Deferred tax expense related to items excluded from GloBE Income or Loss – Article 4.4.1 (a) Aggregates the values of DT-2.1 of the respective jurisdiction or subgroup. |
DT-2.2 | Deferred tax expense related to Disallowed Accruals – Article 4.4.1 (b) Aggregates the values of DT-2.2 of the respective jurisdiction or subgroup. |
DT-2.3 | Deferred tax expense related to Unclaimed Accruals – Article 4.4.1 (b) Aggregates the values of DT-2.3 of the respective jurisdiction or subgroup. |
DT-2.4 | Valuation adjustment or accounting recognition adjustment related to a deferred tax asset – Article 4.4.1 (c) Aggregates the values of DT-2.4 of the respective jurisdiction or subgroup. |
DT-2.5 | Deferred tax expense arising from a re-measurement related to changes in the tax rate – Article 4.4.1 (d) Aggregates the values of DT-2.5 of the respective jurisdiction or subgroup. |
DT-2.6 | Deferred tax expense related to the generation and use of tax credits – Article 4.4.1 (e) Aggregates the values of DT-2.6 of the respective jurisdiction or subgroup. |
DT-2.7 | Substitute Loss Carry Forward DTA or deemed Substitute Loss Carry Forward DTA – Article 4.4.1 (e) Aggregates the values of DT-2.7 of the respective jurisdiction or subgroup. |
DT-2.8 | Disallowed Accruals or Unclaimed Accruals paid during the fiscal year – Article 4.4.2 (a) Aggregates the values of DT-2.8 of the respective jurisdiction or subgroup. |
DT-2.9 | Recapture Deferred Tax Liability paid during the fiscal year – Article 4.4.2 (b) Aggregates the values of DT-2.9 of the respective jurisdiction or subgroup. |
DT-2.10 | Recognition of a loss Deferred Tax Asset not included in the financials – Article 4.4.2 (c) Aggregates the values of DT-2.10 of the respective jurisdiction or subgroup. |
DT-2.11 | Deferred tax expense adjustment resulting from a reduction to a tax rate – Article 4.6.2 Aggregates the values of DT-2.11 of the respective jurisdiction or subgroup. |
DT-2.12 | Deferred tax expense adjustment resulting from an increase to a tax rate – Article 4.6.3 Aggregates the values of DT-2.12 of the respective jurisdiction or subgroup. |
DT-2.13 | Constituent Entities joining and leaving an MNE Group – Article 6.2 Aggregates the values of DT-2.13 of the respective jurisdiction or subgroup. |
DT-2.14 | Deferred tax expense of the UPE that is a Flow-through Entity – Article 7.1 Aggregates the values of DT-2.14 of the respective jurisdiction or subgroup. |
DT-2.15 | Deferred tax expense of the UPE that is subject to Deductible Dividend Regime – Article 7.2 Aggregates the values of DT-2.15 of the respective jurisdiction or subgroup. |
DT-2.16 | Deferred tax adjustment resulting from transactions between Constituent Entities – Article 9.1.3 Aggregates the values of DT-2.16 of the respective jurisdiction or subgroup. |
DT-2 | Sum of Adjustments Aggregates the values of DT-2 of the respective jurisdiction or subgroup. |
DT-3 | Total Deferred Tax Adjustment Amount Aggregates the values of DT-3 of the respective jurisdiction or subgroup. |
DT-4 | Recast to Minimum Rate Aggregates the values of DT-4 of the respective jurisdiction or subgroup. |
DT-5 | Total Deferred Tax Adjustment Amount (recasted) Aggregates the values of DT-5 of the respective jurisdiction or subgroup. |
TCF-1.1 | Excess Negative Tax Expense Carry Forward generated – Article 4.1.5 and 5.2.1 The Excess Negative Tax Expense Amount is created, when the negative Adjusted Covered Taxes exceed the expected Adjusted Covered Taxes. Therefore, the Negative Tax Expense Amount is created only in case of negative Adjusted Covered Taxes. In case of an overall GloBE Loss the Excess Negative Tax Expense Amount is generated as the positive difference between the expected Negative Tax Expense and the Negative Tax Expense. In case of an overall GloBE Income, the Excess Negative Tax Expense Amount is generated as the positive Negative Tax Expense. |
TCF-1.2 | Decrease in Covered Taxes (but not below zero) by the remaining balance of the Excess Negative Tax Expense Carry-forward – Article 4.1.5 and 5.2.1 The Excess Negative Tax Expense Carry-Forward lowers the Adjusted Covered Taxes, if there is a remaining balance of the Excess Negative Tax Expense Carry-forward from prior years (I-1.1) and the GloBE Income and the Adjusted Covered Taxes are positive. The Negative Expense Carry-forward is decreased by the minimum amount of the remaining balance of Excess Negative Tax Expense Carry-Forward or Adjusted Covered Taxes of the current period. |
GL-1.1 | Deferred Tax Income from GloBE Loss generated in current year Deferred Tax Income from a GloBE Loss is generated, in case of a GloBE Loss created in the current period and if the respective election (JE-50) is elected. The Deferred Tax Income on the GloBE Loss is generated in the height of the GloBE Loss multiplied by the minimum tax rate of 15%. |
GL-1.2 | Deferred Tax Expense from GloBE Loss used in current year The Deferred Tax Expense because of the decrease of a GloBE Loss Carry-forward depends on the exercise of the GloBE Loss Election:
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ACT-1 | Adjusted Covered Taxes States the sum of the Current Taxes after Adjustments, the Increase or decrease in Covered Taxes recorded in equity or OCI relating to amounts included in GloBE Income or Loss that will be subject to tax under local rules and the Total Deferred Tax Adjustment Amount (recasted), the calculation is as follows: {CT-3}+{CT-4}+{DT-5}+{TCF-1.1}-{TCF-1.2}+{GL-1.1}-{GL-1.2} |
| Determination of Substance-based Income Exclusion Amount |
CO-1.1 | Relevant Eligible Payroll Costs of Eligible Employees performing activities in the jurisdiction. Aggregates the values of CO-1.1 of the respective jurisdiction or subgroup. |
CO-1.2 | 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. |
CO-1 | Payroll Carve-Out Amount Aggregates the values of CO-1 of the respective jurisdiction or subgroup. |
CO-2.3 | Carrying value of relevant Eligible Tangible Assets located in the jurisdiction. Aggregates the values of CO-2.3 of the respective jurisdiction or subgroup. |
CO-2.4 | 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. |
CO-2 | Tangible Assets Carve-Out Amount Aggregates the values of CO-2 of the respective jurisdiction or subgroup. |
CO-3 | Substance-based Income Exclusion Aggregates the values of CO-3 of the respective jurisdiction or subgroup. |
| Determination of Top-Up Tax |
TT-1.1 | Minimum Tax Rate States the fixed Minimum Tax Rate of 15% |
TT-1.2 | Effective Tax Rate States the Effective Tax Rate by dividing the amount of Adjusted Covered Taxes of the jurisdiction or subgroup with the GloBE Income or Loss, the calculation is as follows: {ACT-1} / {INC-3} * 100 |
TT-1 | Top-Up Tax Percentage States the Top-Up Tax Percentage by deducting the Effective Tax Rate from the Minimum Tax Rate, the calculation is as follows: Max (0 ; {TT-1.1} - {TT-1.2}) |
TT-2.1 | Excess Profits States the Excess Profits by deducting the Substance-based Income Exclusion from the Net GloBE Income, the calculation is as follows: Max (0 ; {INC-3} - {CO-3}) |
TT-2.2 | Additional Current Top-Up Tax States the amount of Additional Current Top-Up Tax because of Excess Negative Tax Expense if the election to use the Excess Negative Tax Expense Carry-forward is not elected. Therefore, the Additional Current Top-Up Tax is triggered, in case of an overall GloBE Loss in the jurisdiction or subgroup and Excess Negative Expense, that is not elected to be carried forward (JE-13) but to be regarded as Additional Current Top-Up Tax in the current fiscal year. |
TT-2.3 | QDMTT payable Aggregates the values of TT-2.3 of the respective jurisdiction or subgroup. |
TT-2 | Preliminary Top-Up Tax States the Preliminary Top-Up Tax by multiplying the Top-Up Tax Percentage with the Excess profits, adding any additional current Top-Up Tax and deducting any QDMTT payable, the calculation is as follows: {TT-1}/100*{TT-2.1}+{TT-2.2}-{TT-2.3} |
TT-3.1 | De Minimis Election: Top-Up Tax is set to zero States the amount of preliminary Top-Up Tax, if the De Minimis Election (JE-41) is exercised. |
TT-3.2 | Safe Harbour Election: Top-Up Tax is set to zero States the amount of preliminary Top-Up Tax, if the Safe Harbour Election (JE-40) is exercised. In case the De Minimis Election and the Safe Harbour Election are both selected, the De Minimis Election overrules the Safe-Harbour Selection. |
TT-3 | Top-Up Tax States the Sum of Top-Up Tax after the exercise of the de Minimis and Safe Harbour Election, the calculation is as follows: {TT-2}-{TT-3.1}-{TT-3.2} |
| Information |
| Excess Negative Tax Expense Carry-Forward |
I-1.1 | Excess Negative Tax Expense Carry-forward from prior years The Excess Negative Tax Expense Carry-forward from prior years is equal to the Excess Negative Tax Expense Carry-Forward remaining for subsequent years (I-1.4) of the prior year. It depends on the previous period snapshot chosen when the calculation was performed. |
I-1.2 | Excess Negative Tax Expense Carry-forward generated in the reporting fiscal year States the Excess Negative Tax Expense Carry-forward generated in the reporting fiscal year, in either the case of Excess Negative Tax Expense and a positive GloBE Income or in case of Excess Negative Tax Expense and a GloBE Loss if the Election for the Carry-forward (JE-13) is exercised. |
I-1.3 | Excess Negative Tax Expense Carry-forward utilised for the reporting fiscal year Equal to TCF-1.2, the Tax Expense Carry-forward utilised in the reporting fiscal year. |
I-1.4 | Excess Negative Tax Expense Carry-forward remaining for subsequent years States the Excess Negative Tax Expense Carry-forward as the Negative Tax Expense Carry-Forward from prior years (I-1.1), adds the Carry-forward generated in the reporting fiscal year (I-1.2) and subtracts the Carry-forward utilised in the reporting fiscal year (I-1.3), the calculation is as follows, {I-1.1}+{I-1.2}-{I-1.3} |
| GloBE Loss Carry-Forward |
I-2.1 | GloBE Loss Carry-Forward from prior years The GloBE Loss Carry-Forward from prior years is equal to the GloBE Loss Carry-Forward remaining for subsequent years (I-2.4) of the prior year. It depends on the previous period snapshot chosen when the calculation was performed. |
I-2.2 | GloBE Loss created in current year States the positive amount of the GloBE Loss of the current period, if the Election for the GloBE Loss is exercised. |
I-2.3 | GloBE Loss used in current year The GloBE Loss utilised in the current year depends on the exercise of the GloBE Loss Election:
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I-2.4 | GloBE Loss Carry-Forward remaining for subsequent years States the GloBE Loss Carry-Forward as the GloBE Loss Carry-Forward from prior years (I-2.1), adds the GloBE Loss Carry-Forward generated in the the current year (I-2.2) and subtracts the GloBE Loss used in the current year (I-2.3), the calculation is as follows, {I-2.1}+{I-2.2}-{I-2.3} |
| Aggregate Asset Gains |
I-3.1 | Aggregate Asset Gains 4th preceding period States the value of Aggregate Asset Gains I-3.2 of the prior period |
I-3.2 | Aggregate Asset Gains 3rd preceding period States the value of Aggregate Asset Gains I-3.3 of the prior period |
I-3.3 | Aggregate Asset Gains 2nd preceding period States the value of Aggregate Asset Gains I-3.4 of the prior period |
I-3.4 | Aggregate Asset Gains 1st preceding period States the value of Aggregate Asset Gains I-3.5 of the prior period |
I-3.5 | Aggregate Asset Gains current period Aggregates the values of I-3.5 of the respective jurisdiction or subgroup. |