Pillar 2 Algorithm - Revision history

Walid ELJAAFARI: /* Development Program */

2023-12-14T08:34:01Z

Development Program

← Older revision		Revision as of 08:34, 14 December 2023
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	Both GitHub and MediaWiki are amazing tools to manage collaborative work and track the progress and modifications that happen with time.		Both GitHub and MediaWiki are amazing tools to manage collaborative work and track the progress and modifications that happen with time.

	The		The detailed to-do list is presented [[Pillar 2 Algorithm Development Program]].

	== Data structure ==		== Data structure ==

Walid ELJAAFARI: /* General logic of the algorithm */

2023-12-14T08:19:16Z

General logic of the algorithm

← Older revision		Revision as of 08:19, 14 December 2023
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	It is also our plan to continue to refine the computational steps that may not be perfectly documented progressively with the publishing of additional guidance as well as the feedback of the community.		It is also our plan to continue to refine the computational steps that may not be perfectly documented progressively with the publishing of additional guidance as well as the feedback of the community.

			== Development Program ==
			The Pillar 2 Algorithm presented in this is an ongoing work and its documentation on this wiki is also a work in progress. It is by no means complete and definitive, and changes will occur in the upcoming weeks and months.

			Both GitHub and MediaWiki are amazing tools to manage collaborative work and track the progress and modifications that happen with time.

			The

	== Data structure ==		== Data structure ==

Walid ELJAAFARI: Update title format

2023-12-12T11:02:54Z

Update title format

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Walid ELJAAFARI: /* Introduction */

2023-12-12T10:51:59Z

Introduction

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	=== Introduction ===		== Introduction ==

	==== Context ====		==== Context ====

Walid ELJAAFARI: /* Macro-step 1 - Scope and Perimeter analysis */

2023-12-12T10:48:50Z

Macro-step 1 - Scope and Perimeter analysis

← Older revision		Revision as of 10:48, 12 December 2023
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	See detailed [[Step-by-step computation for Macro-step 2]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 2]], to review the detailed computational steps.

	===== Macro-step 3 - General Financial data treatments =====		==== Macro-step 3 - General Financial data treatments ====

	===== Purpose =====		===== Purpose =====
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	See detailed [[Step-by-step computation for Macro-step 3]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 3]], to review the detailed computational steps.

	===== Macro-step 4 - Specific election treatments =====		==== Macro-step 4 - Specific election treatments ====

	===== Purpose =====		===== Purpose =====
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	See detailed [[Step-by-step computation for Macro-step 5]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 5]], to review the detailed computational steps.

	===== Macro-step 6 - Charging Mechanisms =====		==== Macro-step 6 - Charging Mechanisms ====

	===== Purpose =====		===== Purpose =====
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	See detailed [[Step-by-step computation for Macro-step 6]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 6]], to review the detailed computational steps.

	===== Macro-step 7 - UTPR computation =====		==== Macro-step 7 - UTPR computation ====

	===== Purpose =====		===== Purpose =====

Walid ELJAAFARI: /* Macro-step 7 - UTPR computation */

2023-12-10T19:15:15Z

Macro-step 7 - UTPR computation

← Older revision		Revision as of 19:15, 10 December 2023
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	===== Purpose =====		===== Purpose =====
	The purpose of the is to .		The purpose of the UTPR computation is to identify the amount of Top-Up Tax not taken into account by the Income Inclusion Rule, and reallocate it across the UTPR Jurisdiction according to the allocation key.

	===== General Logic =====		===== General Logic =====
	In order to perform the .		In order to perform the UTPR computation, the total amount of Top-Up Tax is compared with the amount of Top-Up Tax effectively allocated for payment through the IIR, and the difference is used as a base before reallocation using the formulary apportionment key across all UTPR Jurisdictions.

	===== Data Input =====		===== Data Input =====
	The Data input for Macro-step consists in :		The Data input for Macro-step 7 consists in :

	* The list of ;		* The list of Top-Up Tax amounts from the Macro-step 5 ;
	* The list of		* The list of allocated Top-Up Tax amounts according to the IIR;
			* The input data for the formulary apportionment;
			* The share of UTPR effectively charged in the previous years;

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].
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	The Data output for Macro-step consists in :		The Data output for Macro-step consists in :

	* The ;		* The UTPR amounts affected to each Jurisdictions ;
	* The		* The GloBE Information Return output data
	* The

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].
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	===== Detailed Step by step approach =====		===== Detailed Step by step approach =====
	See detailed [[Step-by-step computation for Macro-step 7]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 7]], to review the detailed computational steps.

	~~===== Step 7.1. - Computation of Total UTPR amount =====~~

	~~===== Step 7.2. - Computation of coefficients per Jurisdictions =====~~

	~~===== Step 7.3. - Final UTPR computation per jurisdiction =====~~

Walid ELJAAFARI: /* Data Input */

2023-12-10T19:01:17Z

Data Input

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	The Data input for Macro-step consists in :		The Data input for Macro-step consists in :

	* The list of ;		* The list of Top-Up Tax computed in Macro-step 5 for each LTCE's ;
	* The ~~list~~ of		* The Matrices of Indirect Ownership interests as well as Controlling Interest;

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].

	===== Data Output =====		===== Data Output =====
	The Data output for Macro-step consists in :		The Data output for Macro-step 5 consists in :

	* The ;		* The list of IPEs and POPEs subject to the IIR ;
	* The		* The amounts of Top-Up Tax due by these Parent entities;
	* The

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].
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	See detailed [[Step-by-step computation for Macro-step 6]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 6]], to review the detailed computational steps.

	=~~==== Step 6.1. - Construction of the "Is in IIR" Matrix =====~~		===== Macro-step 7 - UTPR computation =====

	~~===== Step 6.2. - Identification of potential IPE/POPEs =====~~

	~~===== Step 6.3. - Identification of IPEs and POPEs =====~~

	~~===== Step 6.4. - Construction of Allocable share matrix =====~~

	~~===== Step 6.5. - Exclusion of IIR and Offset mechanism =====~~

	~~===== Step 6.6. - Final charging mechanism of LTCE's TUT to paying entities =====~~

	==== Macro-step 7 - UTPR computation ====

	===== Purpose =====		===== Purpose =====

Walid ELJAAFARI: /* Macro-step 6 - Charging Mechanisms */

2023-12-10T18:55:02Z

Macro-step 6 - Charging Mechanisms

← Older revision		Revision as of 18:55, 10 December 2023
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	===== Purpose =====		===== Purpose =====
	The purpose of the ~~Scope and Perimeter analysis~~ is to .		The purpose of the Charging Mechanisms is to identify the amount of Top-Up Tax attributed to the parent entities of the Low Tax Constituent Entities according to the Income Inclusion Rule.

	===== General Logic =====		===== General Logic =====
	In order to perform the .		In order to perform the computation, the different IPEs and POPEs and their Income Inclusion Ratios in their various subsidiaries are first computed. After this initial step, the exception to the IIR are identified along the shareholding chains, before computing the Allocable shares of Top-Up Tax of each Parent Entity still subject to the IIR in their LTCE subsiaries.

	===== Data Input =====		===== Data Input =====

Walid ELJAAFARI: /* Macro-step 5 - ETR and Top-Up Tax computations */

2023-12-10T18:47:29Z

Macro-step 5 - ETR and Top-Up Tax computations

← Older revision		Revision as of 18:47, 10 December 2023
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	===== Purpose =====		===== Purpose =====
	The purpose of the ETR and Top-Up Tax computations is to compute the ~~different~~ Additional Top-Up Taxes.		The purpose of the ETR and Top-Up Tax computations is to compute the Top-Up Tax in each Jurisdictions and Jurisdiction sub-perimeters after the computation of the various Additional Top-Up Taxes and the Substance-Based Income Exclusion.

	===== General Logic =====		===== General Logic =====
	In order to perform the .		In order to perform the computation, the recalculations are first performed and then the Jurisdictional Top-Up Tax is computed after taking into account the impact of the SBIE, Additional Top-Up Taxes and Qualified Domestic Top-Up Tax. It is then reallocated to the various Constituent Entity according to their positive GloBE Income.

	===== Data Input =====		===== Data Input =====
	The Data input for Macro-step 5 consists in :		The Data input for Macro-step 5 consists in :

	* The list of ;		* The list of Jurisdictions and Jurisdiction sub-perimeters;
	* The list of		* The list of all the GloBE aggregates ;

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].
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	The Data output for Macro-step 5 consists in :		The Data output for Macro-step 5 consists in :

	* The ;		* The Top-Up Tax for each Low Tax Constituent Entity ;
	* The		* The data required by the GIR to document the computation;
	* The

	The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].		The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].
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	See detailed [[Step-by-step computation for Macro-step 5]], to review the detailed computational steps.		See detailed [[Step-by-step computation for Macro-step 5]], to review the detailed computational steps.

	=~~==== Step 5.1. - Construction of Jurisdiction/Sub-group aggregates and indicators =====~~		===== Macro-step 6 - Charging Mechanisms =====

	~~===== Step 5.2. - Computation of Jurisdiction/Sub-group Top-Up Tax =====~~

	~~===== Step 5.3. - Allocation of Top-Up Tax among LTCEs =====~~

	==== Macro-step 6 - Charging Mechanisms ====

	===== Purpose =====		===== Purpose =====

Walid ELJAAFARI: /* Purpose */

2023-12-10T18:23:10Z

Purpose

← Older revision		Revision as of 18:23, 10 December 2023
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	===== Purpose =====		===== Purpose =====
	The purpose of the ~~Scope~~ and ~~Perimeter analysis~~ is to .		The purpose of the ETR and Top-Up Tax computations is to compute the different Additional Top-Up Taxes.

	===== General Logic =====		===== General Logic =====
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	===== Data Input =====		===== Data Input =====
	The Data input for Macro-step consists in :		The Data input for Macro-step 5 consists in :

	* The list of ;		* The list of ;
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	===== Data Output =====		===== Data Output =====
	The Data output for Macro-step consists in :		The Data output for Macro-step 5 consists in :

	* The ;		* The ;