JE-10   

Aggregate Asset Gain Election (Article 3.2.6)

If the option is exercised, all values entered at level of the individual CEs at INC-2.16 and CT-2.12 are taken into account in the CE Calculation and in the Jurisdictional Blending. If the option is not exercised, any values entered in these lines will not be taken into account.

The option has no effect on lines I-3 of the CE Calculation and the Jurisdictional Blending. Gains and losses on immovable assets are collected at the CE level regardless of whether the election is exercised and are aggregated and carried forward as part of the Jurisdictional Blending. These informative values are provided to decide on the exercise of the election.

JE-11  

Immaterial decrease in Covered Taxes Election (Article 4.6.1)

Only informational. No effect on the calculation. The import or manual input needs to be made according to the respective legislation in advance.

JE-12

Election not to apply the Substance-based Income Exclusion (Article 5.3.1)

If the option is exercised, all values entered at level of the individual CEs in the dialogue “Substance-based Income Exclusion” are not taken into account in the CE Calculation and in the Jurisdictional Blending. Therefore, the Carve-Out Amount in the CE Calculation as well as the Jurisdictional Blending is set to zero. If the option is not exercised, any values entered in these lines will be taken into account.

JE-13

Negative Tax Expense Carry-forward

If the option is exercised, an Excess Negative Tax Expense generated in case of a GloBE Loss, is part of the Excess Negative Tax Expense Carry-forward (I-1.2) instead of the Additional Top-Up Tax Amount (TT-2.2).

The election has no effect on the negative Tax Expense amount in TCF-1.1, that is automatically generated if the negative tax expense exceeds the expected negative tax expense. Instead, the election just affects if the amount of Negative Tax Expense that is generated in case of an overall GloBE loss (INC-3 < 0) is considered as Additional Top-Up Tax (TT-2.2) in the current year or carried forward to subsequent years and considered as Negative Tax Expense Carry-Forward generated in the current year. (I-1.2)

JE-14   

Deemed Distribution Tax election (Article 7.3.1)

Only informational. No effect on the calculation. The import or manual input needs to be made according to the respective legislation in advance.

JE-30

Equity Investment Inclusion Election (Article 3.2.1(c))

Only informational. No effect on the calculation. The import or manual input needs to be made according to the respective legislation in advance.

JE-31

Stock-based compensation election (Article 3.2.2)

If the option is exercised, all values entered at level of the individual CEs at INC-2.12 are taken into account in the CE Calculation and in the Jurisdictional Blending. If the option is not exercised, any values entered in these lines will not be taken into account.

JE-32

Realisation principle election (Article 3.2.5)

If the option is exercised, all values entered at level of the individual CEs at INC-2.15 are taken into account in the CE Calculation and in the Jurisdictional Blending. If the option is not exercised, any values entered in these lines will not be taken into account.

JE-33

Intra-group transactions election (Article 3.2.8)

Only informational. No effect on the calculation. The import or manual input needs to be made according to the respective legislation in advance.

JE-40

CbCR Transitional Safe Harbor

If the option is exercised, any amount of Top-Up Tax calculated for the Jurisdiction is set to zero in line TT-3.2 of the Jurisdictional Blending.

If both, the CbCR Transitional Safe Harbor Election as well as the De Minimis Election is exercised, the Top-Up Tax is set to zero in line TT-3.1.

JE-41

Election to apply the de minimis exclusion for the Reporting Fiscal Year

If the option is exercised, any amount of Top-Up Tax calculated for the Jurisdiction is set to zero in line TT-3.1 of the Jurisdictional Blending. If both, the CbCR Transitional Safe Harbor Election as well as the De Minimis Election is exercised, the Top-Up Tax is set to zero in line TT-3.1.

JE-50

GloBE Loss Election (Article 4.5)

If the option is exercised, the Total Deferred Tax Adjustment Amount, as well as every Data Point regarding the Deferred Taxes and Adjustments of the CEs in the jurisdiction, is set to zero. This is shown in the CE Calculation as well as the Jurisdictional Blending.

If the election is exercised in the case of an overall loss in the jurisdiction the calculations will show a GloBE Loss Carry-Forward equal to the positive amount of the GloBE Loss (I-2.2) as well as Deferred Tax Income from the GloBE Loss generated in the current year equal to the amount of the GloBE loss multiplied by the minimum rate of 15%. (GL-1.1) The Deferred Tax Income adds to the sum of the Adjusted Covered Taxes in the Jurisdictional Blending (instead of the Total Deferred Tax Adjustment Amount)

If the Election is exercised in case of an overall GloBE Income, an eventual amount of GloBE Loss Carry-Forward from earlier years (I-2.1) is used in the current year and leads to Deferred Tax Expense (GL-1.2) that lowers the amount of Adjusted Covered Taxes of the Jurisdiction. The Deferred Tax Expense is the lesser amount of the GloBE Income multiplied by the Minimum Tax Rate and the GloBE Loss Carry-Forward multiplied by the Minimum Tax Rate.

If the Election is not exercised and there is still a GloBE Loss Carry-Forward from prior years at the beginning of the period, this is fully (independently from the amount of GloBE Income) used in the current year by multiplying the GloBE Loss Carry-Forward with the Minimum Tax Rate. (GL-1.2)

JE-60

Identification of subgroups (if any)

Possibility to give information for eventual subgroups in the jurisdiction, such as Joint Venture.