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  • C3 - De Minimis Check

    C3 - De Minimis Check

    The De Minimis Check states if the permanent Safe Harbour is successful because the GloBE Revenue and the GloBE Income are below the GloBE thresholds.

    The calculation of the average GloBE Revenue and Average GloBE Income is performed on a CE basis as part of the CE-Calculation. The De Minimis Check aggregates the average GloBe Revenue und average GloBE Income for the respective jurisdiction and subgroup and tests if the values are below the GloBE thresholds.

    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.

     

    Average of the available Fiscal Years

    DM-4.1

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

    States the aggregated amount of the Average Revenue of the CE-Calculations (DM-4.1) on a per country and per Reporting Dimension basis.

    DM-4.2

    GloBE Revenue - Average of the available Fiscal Years

    States the aggregated amount of the Average GloBE Revenue of the CE-Calculations (DM-4.2) on a per country and per Reporting Dimension basis.

    DM-4.3

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

    States the aggregated amount of the Average Financial Accounting Net Income (or Loss) of the CE-Calculations (DM-4.3) on a per country and per Reporting Dimension basis.

    DM-4.4

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

    States the aggregated amount of the Average GloBE Income (or Loss) of the CE-Calculations (DM-4.4) on a per country and per Reporting Dimension basis.

     

    De Minimis Test

    DM-5.1

    GloBE Revenue - Average of the available Fiscal Years

    States the aggregated amount of the Average GloBE Revenue of the CE-Calculations (DM-4.2) on a per country and per Reporting Dimension basis.

    Is equal to the DM-4.2 of the De Minimis Check

    DM-5.2

    Average GloBE Revenue threshold

    Is 10’000’000 according to the OECD Model Rules.

    DM-5.3

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

    States the aggregated amount of the Average GloBE Income of the CE-Calculations (DM-4.4) on a per country and per Reporting Dimension basis.

    Is equal to the DM-4.2 of the De Minimis Check

    DM-5.4

    Average GloBE Income threshold

    Is 1’000’000 according to the OECD Model Rules.

     

     

    DM-6

    De Minimis Test successful?

    The De Minimis Test is successful if both, the aggregated average GloBE Revenue as well as the aggregted average GloBE Income are below the respective threshold.