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    • C2 - CE Calculations

    Owned by Sebastian Roland
    Last updated: Mar 08, 2024 by Alexandra Yussif
    19 min read

    C2 - CE Calculations

    The CE Calculations give an overview about the relevant values of each CE on a stand-alone basis. In general, this is the value of the “Total” column of the respective dialogue.

    At the begin of the calculation there is an overview on how election rights were exercised for each CE in this snapshot. After that, there are the relevant values for the determination of the GloBE Income, Covered Taxes, Substance-based income exclusion as well as some additional information and the values to calculate the De Minimis Exclusion.

    Some of these values are connected with elections, depending on the type of election. If elections are relevant for a specific line item, it is specified in the table below. For more information on elections please see the section Group Data Collection for information about jurisdictional elections and the section Entity Election and general information (Entity Data Collection) regarding Entity Elections.

    Some data points are also linked to status information of the respective entity. Nearly all data points are linked to the status “Excluded Entity”. If one of the check boxes of AMAE20 to AMAE26 is active, the entity is regarded as excluded, and every value is set to zero. A similar effect is the checkbox of AMAE00 – if an entity is not a CE for Pillar 2 purposes, all values are set to zero as well.

    Because election rights and the status of the CE is taken into account in the CE Calculations, the calculation results e.g. the GloBE Income or the Adjusted Covered Taxes can vary from the calculation results of the Entity Data Collection dialogues.

     

    Determination of Net GloBE Income (Loss)

    INC-1.1

    Aggregate Financial Accounting Net Income or Loss amount

    INC-1.2

    Allocations from another CE to this CE

    INC-1.3

    Allocations from this CE to another CE

    INC-1

    Aggregate Financial Accounting Net Income or Loss amount after allocations in Articles 3.4 and 3.5

    States for each entity the “Total” value of the entity data collection in INC-1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.1

    Net Taxes Expense - Article 3.2.1 (a)

    States for each entity the “Total” value of the entity data collection in INC-2.1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.2

    Excluded Dividends – Article 3.2.1 (b)

    States for each entity the “Total” value of the entity data collection in INC-2.2.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.3

    Excluded Equity Gain or Loss – Article 3.2.1 (c)

    States for each entity the “Total” value of the entity data collection in INC-2.3.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.4

    Included Revaluation Method Gain or Loss – Article 3.2.1 (d)

    States for each entity the “Total” value of the entity data collection in INC-2.4.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.5

    Gain or loss from disposition of assets and liabilities excluded under Article 6.3 – Article 3.2.1 (e)

    States for each entity the “Total” value of the entity data collection in INC-2.5.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.6

    Asymmetric Foreign Currency Gains or Losses – Article 3.2.1 (f)

    States for each entity the “Total” value of the entity data collection in INC-2.6.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.7

    Policy Disallowed Expenses – Article 3.2.1 (g)

    States for each entity the “Total” value of the entity data collection in INC-2.7.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.8

    Prior Period Errors – Article 3.2.1 (h)

    States for each entity the “Total” value of the entity data collection in INC-2.8.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.9

    Changes in Accounting Principles – Article 3.2.1(h)

    States for each entity the “Total” value of the entity data collection in INC-2.9.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.10

    Accrued Pension Expense – Article 3.2.1 (i)

    States for each entity the “Total” value of the entity data collection in INC-2.10.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.11

    Debt releases - Article 3.2.1

    States for each entity the “Total” value of the entity data collection in INC-2.11.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Debt Release Election (EE-2).

    INC-2.12

    Stock-based compensation – Article 3.2.2

    States for each entity the “Total” value of the entity data collection in INC-2.12.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Stock-based compensation Election (JE-31).

    INC-2.13

    Arm’s length adjustments – Article 3.2.3

    States for each entity the “Total” value of the entity data collection in INC-2.13.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.14

    Qualified Refundable Tax Credit – Article 3.2.4

    States for each entity the “Total” value of the entity data collection in INC-2.14.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.15

    Election for Gains and losses using realisation principle – Article 3.2.5

    States for each entity the “Total” value of the entity data collection in INC-2.15.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Realisation principal election (JE-32).

    INC-2.16

    Election for Adjusted Asset Gain – Article 3.2.6

    States for each entity the “Total” value of the entity data collection in INC-2.16.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Aggregate Asset Gain election (JE-10).

    INC-2.17

    Intragroup Financing Arrangement expense – Article 3.2.7

    States for each entity the “Total” value of the entity data collection in INC-2.17.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.18

    Election for intragroup transactions in same jurisdiction – Article 3.2.8

    States for each entity the “Total” value of the entity data collection in INC-2.18.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the intra-group transaction election (JE-33).

    INC-2.19

    Insurance company taxes charged to policyholders – Article 3.2.9

    States for each entity the “Total” value of the entity data collection in INC-2.19.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.20

    Increase/decrease to equity attributed to Additional Tier One Capital distributions paid/payable or received/receivable – Article 3.2.10.

    States for each entity the “Total” value of the entity data collection in INC-2.20.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.21

    Constituent Entities joining and leaving an MNE Group – Article 3.2.11 and 6.2.

    States for each entity the “Total” value of the entity data collection in INC-2.21.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.22

    Reduction of GloBE Income of the UPE that is a Flow-through Entity – Article 3.2.11 and 7.1.

    States for each entity the “Total” value of the entity data collection in INC-2.22.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    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.

    States for each entity the “Total” value of the entity data collection in INC-2.23.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC-2.24

    Taxable Distribution Method election – Article 3.2.11 and 7.6

    States for each entity the “Total” value of the entity data collection in INC-2.24.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Taxable distribution method election (EE-8).

    INC-2.25

    International Shipping Income – Article 3.3

    States for each entity the “Total” value of the entity data collection in INC-2.25.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    INC.2.26

    Transactions between Constituent Entities - Article 9.1.3

    INC.2

    Sum of Adjustments

    States the Sum of all adjustments above, the calculation is as follows:

    {INC-2.1}-{INC-2.2}-{INC-2.3}+{INC-2.4}-{INC-2.5}-{INC-2.6}+{INC-2.7}-{INC-2.8}-{INC-2.9}+{INC-2.10}-{INC-2.11}+{INC-2.12}-{INC-2.13}+{INC-2.14}+{INC-2.15}+{INC-2.16}+{INC-2.17}-{INC-2.18}-{INC-2.19}+{INC-2.20}-{INC-2.21}-{INC-2.22}-{INC-2.23}+{INC-2.24}-{INC-2.25}+{INC-2.26}

    INC-3

    Net GloBE Income (Loss)

    States the sum of the Financial Accounting Net Income or Loss and the Sum of Adjustments, the calculation is as follows:

    {INC-1}+{INC-2}

     

    Determination of Covered Current Taxes

    CT-1.1

    Current tax expense with respect to Covered Taxes

    CT-1.2

    Allocations from another CE to this CE

    CT-1.3

    Allocations from this CE to another CE

    CT-1.4

    CFC Tax Expense and Taxes on distributions from another CE to this CE

    CT-1.5

    CFC Tax Expense and Taxes on distributions from this CE to another CE

    CT-1

    Current tax expense with respect to Covered Taxes after allocations in Article 4.3

    States for each entity the “Total” value of the entity data collection in CT-1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.1

    Covered Tax accrued as an expense in the profit before taxation in the financial accounts - Article 4.1.2 (a)

    States for each entity the “Total” value of the entity data collection in CT-2.1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    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

    States for each entity the “Total” value of the entity data collection in CT-.2.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.3

    Covered Taxes for uncertain tax position recorded as a reduction to Covered Taxes in prior year – Article 4.1.2 (c)

    States for each entity the “Total” value of the entity data collection in CT-2.3.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.4

    Qualified Refundable Tax Credit recorded as a reduction to current tax expense – Article 4.1.2 (d)

    States for each entity the “Total” value of the entity data collection in CT-2.4.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.5

    Qualified Flow-through Tax Benefits of Qualified Ownership Interests - Article 3.2.1 (c)

    States for each entity the “Total” value of the entity data collection in CT-2.5.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.6

    Current tax expense on income excluded from GloBE Income or Loss – Article 4.1.3 (a)

    States for each entity the “Total” value of the entity data collection in CT-2.6.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.7

    Non-Qualified Refundable Tax Credit not recorded as a reduction to current tax expense – Article 4.1.3 (b)

    States for each entity the “Total” value of the entity data collection in CT-2.7.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    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)

    States for each entity the “Total” value of the entity data collection in CT-2.8.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.9

    Current tax expense related to uncertain tax position– Article 4.1.3 (d)

    States for each entity the “Total” value of the entity data collection in CT-2.9.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.10

    Current tax expense not expected to be paid within three years – Article 4.1.3 (e)

    States for each entity the “Total” value of the entity data collection in CT-2.10.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.11

    Post-filing adjustments – Article 4.6.1

    States for each entity the “Total” value of the entity data collection in CT-2.11.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.12

    Covered Taxes relating to Net Asset Gain or Net Asset Loss – Article 3.2.6

    States for each entity the “Total” value of the entity data collection in CT-2.12.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Aggregate Asset Gain election (JE-10).

    CT-2.13

    Reduction of Covered Taxes of the UPE that is a Flow-through Entity – Article 7.1

    States for each entity the “Total” value of the entity data collection in CT-2.13.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.14

    Covered Taxes for GloBE Income of the UPE that is reduced under a Deductible Dividend Regime – Article 7.2.2

    States for each entity the “Total” value of the entity data collection in CT-2.14.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.15

    Deemed Distribution Tax– Article 7.3

    States for each entity the “Total” value of the entity data collection in CT-2.15.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    CT-2.16

    Taxable Distribution Method election – Article 7.6

    States for each entity the “Total” value of the entity data collection in CT-2.16.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity didn’t elect the Taxable distribution method election (EE-8).

    CT-2

    Sum of Adjustments

    States the Sum of all adjustments above, the calculation is as follows:

    {CT-2.1}+{CT-2.2}+{CT-2.3}+{CT-2.4}+{CT-2.5}-{CT-2.6}-{CT-2.7}-{CT-2.8}-{CT-2.9}-{CT-2.10}-{CT-2.11}-{CT-2.12}-{CT-2.13}-{CT-2.14}+{CT-2.15}+{CT-2.16}

    CT-3

    Current Taxes after Adjustments

    States the sum of the Current tax expense with respect to Covered Taxes and the Sum of Adjustments, the calculation is as follows:

    {CT-1}+{CT-2}

    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)

    States for each entity the “Total” value of the entity data collection in CT-4.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

     

    Determination of Covered Deferred Taxes

    DT-1

    Deferred tax expense amount

    States for each entity the “Total” value of the entity data collection in DT-1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.1

    Deferred tax expense related to items excluded from GloBE Income or Loss – Article 4.4.1 (a)

    States for each entity the “Total” value of the entity data collection in DT-2.1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.2

    Deferred tax expense related to Disallowed Accruals– Article 4.4.1 (b)

    States for each entity the “Total” value of the entity data collection in DT-2.2.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.3

    Deferred tax expense related to Unclaimed Accruals – Article 4.4.1 (b)

    States for each entity the “Total” value of the entity data collection in DT-2.3.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.4

    Valuation adjustment or accounting recognition adjustment related to a deferred tax asset – Article 4.4.1 (c)

    States for each entity the “Total” value of the entity data collection in DT-2.4.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.5

    Deferred tax expense arising from a re-measurement related to changes in the tax rate – Article 4.4.1 (d)

    States for each entity the “Total” value of the entity data collection in DT-2.5.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.6

    Deferred tax expense related to the generation and use of tax credits – Article 4.4.1 (e)

    States for each entity the “Total” value of the entity data collection in DT-2.6.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.7

    Substitute Loss Carry Forward DTA or deemed Substitute Loss Carry Forward DTA – Article 4.4.1 (e)

    States for each entity the “Total” value of the entity data collection in DT-2.7.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.8

    Disallowed Accruals or Unclaimed Accruals paid during the fiscal year – Article 4.4.2 (a)

    States for each entity the “Total” value of the entity data collection in DT-2.8.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.9

    Recapture Deferred Tax Liability paid during the fiscal year– Article 4.4.2 (b)

    States for each entity the “Total” value of the entity data collection in DT-2.9.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.10

    Recognition of a loss Deferred Tax Asset not included in the financials – Article 4.4.2 (c)

    States for each entity the “Total” value of the entity data collection in DT-2.10.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.11

    Deferred tax expense adjustment resulting from a reduction to a tax rate – Article 4.6.2

    States for each entity the “Total” value of the entity data collection in DT-2.11.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.12

    Deferred tax expense adjustment resulting from an increase to a tax rate – Article 4.6.3

    States for each entity the “Total” value of the entity data collection in DT-2.12.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.13

    Constituent Entities joining and leaving an MNE Group – Article 6.2

    States for each entity the “Total” value of the entity data collection in DT-2.13.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.14

    Deferred tax expense of the UPE that is a Flow-through Entity – Article 7.1

    States for each entity the “Total” value of the entity data collection in DT-2.14.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.15

    Deferred tax expense of the UPE that is subject to Deductible Dividend Regime – Article 7.2

    States for each entity the “Total” value of the entity data collection in DT-2.15.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2.16

    Deferred tax adjustment resulting from transactions between Constituent Entities – Article 9.1.3

    States for each entity the “Total” value of the entity data collection in DT-2.16.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-2

    Sum of Adjustments

    States the Sum of all adjustments above, the calculation is as follows:

    -{DT-2.1}-{DT-2.2}-{DT-2.3}-{DT-2.4}-{DT-2.5}-{DT-2.6}+{DT-2.7}+{DT-2.8}+{DT-2.9}-{DT-2.10}-{DT-2.11}-{DT-2.12}+{DT-2.13}-{DT-2.14}-{DT-2.15}+{DT-2.16}

    DT-3

    Total Deferred Tax Adjustment Amount

    States the sum of the Deferred Tax Expense Amount and the Sum of Adjustments, the calculation is as follows:

    {DT-1}+{DT-2}

    DT-R1

    Automatic Recast Amount

    DT-4.1

    Thereof calculated at the Entity tax rate

    DT-4.2

    Entity tax rate

    DT-4.3

    Thereof recorded at a different tax rate - A

    DT-4.4

    Tax Rate - A

    DT-4.5

    Thereof recorded at a different tax rate - B

    DT-4.6

    Tax Rate - B

    DT-R2

    Manual Recast Amount

    DT-4.7

    Manual Recast Amount instead of automatic Recast

    DT-4.8

    Manual Recast Amount

    DT-4

    Recast to Minimum Rate

    States for each entity the “Total” value of the entity data collection in DT-2.16.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected the GloBE Loss Election (JE-50).

    DT-5

    Total Deferred Tax Adjustment Amount (recasted)

    States the sum of the Total Deferred Tax Adjustment Amount and the Recast Amount, the calculation is as follows:

    {DT-3}-{DT-4}

    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}

     

    Determination of Substance-based Income Exclusion Amount

    CO-1.1

    Relevant Eligible Payroll Costs of Eligible Employees performing activities in the jurisdiction.

    States for each entity the “Total” value of the entity data collection in CO-1.1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected not to apply the Substance-based Income Exclusion (JE-12)

    CO-1.2

    Application of relevant mark-up percentage for the Reporting Fiscal Year

    States the mark-up percentage relevant for Eligible Payroll Costs, in dependence of the date in GEN-1.2 “Start Date of the Reporting Fiscal Year”.  

    CO-1

    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:

    {CO-1.1}*{CO-1.2}

    CO-2.1

    Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the beginning of the reporting year.

    States for each entity the “Total” value of the entity data collection in CO-2.1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected not to apply the Substance-based Income Exclusion (JE-12)

    CO-2.2

    Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the end of the reporting year.

    States for each entity the “Total” value of the entity data collection in CO-2.2.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    Is set to zero if the Entity elected not to apply the Substance-based Income Exclusion (JE-12)

    CO-2.3

    Carrying value of relevant Eligible Tangible Assets located in the jurisdiction.

    States for each CE the arithmetic means 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:

    ({CO-2.1}+{CO-2.1})/2

    CO-2.4

    Application of relevant mark-up percentage for the Reporting Fiscal Year

    States the mark-up percentage relevant for Eligible Tangible Assets, in dependence of the date in GEN-1.2 “Start Date of the Reporting Fiscal Year”. 

    CO-2

    Tangible Assets Carve-Out Amount

    States for each entity the Amount of Eligible Payroll Costs multiplied by the relevant mark-up percentage.

    {CO-2.1}*{CO-2.2}

    CO-3

    Substance-based Income Exclusion

    States for each entity the sum of the Payroll Carve-Out Amount and the Tangible Assets Carve-Out Amount, the calculation is as follows:

    {CO-1}+{CO-2}

    TT-CE

    Information for the Top-Up Tax Calculation

    TT-2.3

    QDMTT payable

    States for each entity the “Total” value of the entity data collection in QDMTT-2.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

     

    Information

    I-3

    Asset Gains

    States for each entity the “Total” value of the entity data collection in AG-1.

    Is set to zero if the entity is an excluded entity, that didn’t elect not to be treated as an Excluded Entity (EE-4).

    This is not dependent of how the Aggregate asset gain election (JE-10) is exercised.

     

    De Minimis Information

    DM-1.1

    Revenue (Financial Accounts) - Reporting Fiscal Year

    States for each entity the “Total” value of the entity data collection in Min-1.1.

    DM-1.2

    GloBE Revenue - Reporting Fiscal Year

    States for each entity the “Total” value of the entity data collection in Min-1.3.

    DM-1.3

    Financial Accounting Net Income (or Loss) - Reporting Fiscal Year

    States for each entity the value of the CE-Calculations in INC-1.

    DM-1.4

    GloBE Income (or Loss) - Reporting Fiscal Year

    States for each entity the value of the CE-Calculations in INC-3.

    DM-2.1

    Revenue (Financial Accounts) - 1st preceding Fiscal Year (if applicable)

    States for each entity the value of DM-1.1 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-2.2

    GloBE Revenue - 1st preceding Fiscal Year (if applicable)

    States for each entity the value of DM-1.2 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-2.3

    Financial Accounting Net Income (or Loss) - 1st preceding Fiscal Year (if applicable)

    States for each entity the value of DM-1.3 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-2.4

    GloBE Income (or Loss) - 1st preceding Fiscal Year (if applicable)

    States for each entity the value of DM-1.4 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-3.1

    Revenue (Financial Accounts) - 2nd preceding Fiscal Year (if applicable)

    States for each entity the value of DM-2.1 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-3.2

    GloBE Revenue - 2nd preceding Fiscal Year (if applicable)

    States for each entity the value of DM-2.1 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-3.3

    Financial Accounting Net Income (or Loss) - 2nd preceding Fiscal Year (if applicable)

    States for each entity the value of DM-2.1 of the previous period Snapshot. A previous period snapshot has to be elected.

    DM-3.4

    GloBE Income (or Loss) - 2nd preceding Fiscal Year (if applicable)

    States for each entity the value of DM-2.1 of the previous period Snapshot. A previous period snapshot has to be elected.

    FYALL

    Fiscal Years not available

    States for each entity the fiscal years of the last two periods, in which the CE wasn’t part of the calculation. The fiscal years not available are necessary to calculate the average of the available fiscal years.

    DM-4.1

    Revenue (Financial Accounts) - Average of the available Fiscal Years

    Average of the Revenue of the Reporting Fiscal Year and the two preceding years, if those are available. If Fiscal Years from earlier periods are not available, the arithmetical mean is just calculated by dividing the cumulated revenue by the numbers of Fiscal Years available.  

    DM-4.2

    GloBE Revenue - Average of the available Fiscal Years

    Average of the GloBE Revenue of the Reporting Fiscal Year and the two preceding years, if those are available. If Fiscal Years from earlier periods are not available, the arithmetical mean is just calculated by dividing the cumulated revenue by the numbers of Fiscal Years available. 

    DM-4.3

    Financial Accounting Net Income (or Loss) - Average of the available Fiscal Years

    Average of the Financial Accounting Net Income (or Loss) of the Reporting Fiscal Year and the two preceding years, if those are available. If Fiscal Years from earlier periods are not available, the arithmetical mean is just calculated by dividing the cumulated revenue by the numbers of Fiscal Years available. 

    DM-4.4

    GloBE Income (or Loss) - Average of the available Fiscal Years

    Average of the GloBE Income (or Loss) of the Reporting Fiscal Year and the two preceding years, if those are available. If Fiscal Years from earlier periods are not available, the arithmetical mean is just calculated by dividing the cumulated revenue by the numbers of Fiscal Years available.