OECD-Standard

Entity Election and General Information

In this dialogue general information of the CEs can be imported or manually adjusted. This contains especially the elections that can be elected at the level of the constituent entity, but also information that are necessary for Jurisdictional elections, regarding a qualified domestic minimum Top-Up Tax or the Accounting Standard.

Simplified jurisdictional reporting framework

EE-1 Does the MNE Group elect to apply the transitional simplified jurisdictional reporting framework?

Only informational.

Annual Elections

The annual elections only apply to the current reporting period and can be selected differently in each year.

EE-2 Debt Release election (Article 3.2.1)

If the option is exercised, the value entered at INC-2.11 is taken into account for the CE Calculation and the Jurisdictional Blending. If the option is not exercised, any values entered in this line will not be taken into account.

EE-3 Unclaimed Accrual Election (Article 4.4.7)

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

Five-year Elections

The five-year elections apply for the period of five years and can’t be selected differently in this period.

EE-4 Not treating an Entity as an Excluded Entity election (Article 1.5.3)

If the election is exercised, an Excluded Entity’s values are included in the CE-Calculation and the Jurisdictional Blending. Usually Excluded Entity’s values are set to zero in the CE-Calculation and therefore not part of the aggregated sum in the Jurisdictional Blending. The Exclusion is linked to the Master Data Points and the Election of one of the options from AMAE20 to AMAE26. Anyway, with the election of EE-4, the data entries in the excluded entities are part of the CE-Calculation as well as the Jurisdictional Blending despite their status is related to exclusion with AMAE20 to AMAE26.

EE-5 Inclusion of all dividends with respect to Portfolio Shareholdings (Article 3.2.1 (b))

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

EE-6 Treating foreign exchange gains or losses attributable to hedging as an Excluded Equity Gain or Loss (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.

EE-7 Investment entity tax transparency election (Article 7.5)

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

CbCR Safe Harbor

In this dialogue the relevant information for the Simplified ETR test and the De Minimis Exclusion for the Safe Harbor Rules of the Transition Phase is collected. (C1 – Safe Harbor Check) The data added here needs to be in line with the Country-by-Country-Report of the Entity. The import possibilities are equal to the other dialogues, nevertheless for this dialogue it is underlined, that the import of the Country-by-Country data from the CbCR Module of the GTC is also possible.

The data needed for the third Safe Harbor Rule of the Transition Phase, the substance-based income exclusion, is collected in the dialogue “Substance-based Income Exclusion”.

Substance-based Income Exclusion

In this dialogue the relevant information for the Substance-based Income Exclusion is collected. This information is needed for the C1 – Safe Harbor Check, where one of the three Safe Harbor Rules of the Transition Phase is linked to the so called Carve-Out Amount. It is also needed to calculate the Carve-Out amount on a CE-basis for the lines CO-1 to CO-3 of the C2 – CE Calculations as well as the C4 – Jurisdictional Blending. This information is necessary to calculate the Excess Profits and the Top-Up Tax.

The dialogue is split in two parts, the first for the information for the “Payroll Carve-Out Amount” the second for the information for the “Tangible Asset Carve-Out Amount”. The tangible Asset Carve-Out Amount is calculated as the mean of the Tangible Asset Carve-Out Amount of the last year and the current year in the calculations, therefore it is crucial, that there is a prior period with currency information of the prior period. In the calculation, the Tangible Asset Carve-Out Amount at the beginning of the year will be transformed to the main currency by using the ultimo exchange rate of the prior year and the Tangible Asset Carve-Out Amount of the current year will be recalculated using the ultimo exchange rate of the current year. After that the mean of the two recalculated values states the basis for the overall Tangible Assets Carve-Out Amount.

Please note, that you can add the information despite you may elect the option not to applicate the Substance-based income exclusion. If elected, the Substance-based Income Exclusion amount will be zero despite eventual entries in this dialogue.

GloBE Income or Loss

In this dialogue the relevant information to calculate the GloBE Income of the CEs (C2 – CE-Calculations) and the jurisdictions (C4 – Jurisdictional Blending) is collected. Some of the entries will not be included in the calculations if elections are exercised. The data point entry, e.g. by import, can be made nevertheless! This gives the possibility to first import or adjust the entries without the consideration of elections and then decide on whether to exercise the election with the given data. For more information on elections, please read the section on Entity Election and general information. Also, if CEs have a special status, e.g. Excluded Entities or entities that are not a Constituent Entity for Pillar 2 purposes, entries in this section may not be part of the C2 – CE-Calculations and the C4 – Jurisdictional Blending. For more information on CE’s status and their implications for the calculation, please read the section on Entity Master Data.

Current Taxes

In this dialogue the relevant information to calculate the Covered Current Taxes of the CEs (C2 – CE-Calculations) and the jurisdictions (C4 – Jurisdictional Blending) is collected. Some of the entries will not be included in the calculations if elections are exercised. The data point entry, e.g. by import, can be made nevertheless! This gives the possibility to first import or adjust the entries without the consideration of elections and then decide on whether to exercise the election with the given data. For more information on elections, please read the section on Entity Election and general information. Also, if CEs have a special status, e.g. Excluded Entities or entities that are not a Constituent Entity for Pillar 2 purposes, entries in this section may not be part of the C2 – CE-Calculations and the C4 – Jurisdictional Blending. For more information on CE’s status and their implications for the calculation, please read the section on Entity Master Data.

Deferred Taxes

In this dialogue the relevant information to calculate the Covered Deferred Taxes of the CEs (C2 – CE-Calculations) and the jurisdictions (C4 – Jurisdictional Blending) is collected. Some of the entries will not be included in the calculations if elections are exercised. The data point entry, e.g. by import, can be made nevertheless! This gives the possibility to first import or adjust the entries without the consideration of elections and then decide on whether to exercise the election with the given data. For more information on elections, please read the section on Entity Election and general information. Also, if CEs have a special status, e.g. Excluded Entities or entities that are not a Constituent Entity for Pillar 2 purposes, entries in this section may not be part of the C2 – CE-Calculations and the C4 – Jurisdictional Blending. For more information on CE’s status and their implications for the calculation, please read the section on Entity Master Data.

An important part of calculating the Total Deferred Tax Adjustment Amount is the recast of the Deferred Tax Expense Amount to the minimum tax rate of 15%. The recast is performed in this dialogue in DT-3 to DT-4. In principle the recast is performed by dividing the Total Deferred Tax Adjustment Amount before recast (DT-3) with the Entity Tax rate (DT-4.1) and multiplying it with the minimum tax rate, if it exceeds the minimum tax rate of 15%. Because not all Deferred Taxes were calculated with the same tax rate, it is possible to extract Deferred Tax Expense (+ data entry) or Income (- data entry) in the lines DT-4.3 und DT-4.5 and assign specific tax rates (DT-4.4 and DT-4.6). The residual amount of Deferred Tax Expense (DT-4.1) is adjusted by the extracted Expense or Income automatically.

Top-up Tax Allocation

In this dialogue the Inclusion ratio of the CE is collected. The value impacts the Income Inclusion of the C-5 - Top-Up Tax Calculation.