C5 - Top-Up Tax Allocation

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

 

Low-taxed CE allocated Top-Up Tax

TA-1

Jurisdiction or Subgroup
States the Jurisdiction or Subgroup of the respective CE.

TA-2.1

Positive GloBE Income of the low-taxed CE or member of Joint Venture Group
States the GloBE Income {INC-3} of the CE-Calculation if positive, for each CE.

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