Step-by-step computation for Macro-step 2 - Revision history

Walid ELJAAFARI: /* Step 2.1. - Identification of the Non Material Constituent Entities */

2024-01-17T08:28:59Z

Step 2.1. - Identification of the Non Material Constituent Entities

← Older revision		Revision as of 08:28, 17 January 2024
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	=== Step 2.1. - Identification of the Non Material Constituent Entities ===		=== Step 2.1. - Identification of the Non Material Constituent Entities ===
			Draft :

			All entities that are "not consolidated" for materiality reasons, detailed test on accounting standards is being added.

			In this case PBT is fed with Revenue for all following computation.

	=== Step 2.2. - Computation of the various available tests ===		=== Step 2.2. - Computation of the various available tests ===
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	==== Micro-step 2.2.2. - QDMTT Safe Harbour ====		==== Micro-step 2.2.2. - QDMTT Safe Harbour ====
			Draft

			Available if the Tested Jurisdiction has put in place a QDMTT

	==== Micro-step 2.2.3. - Transitional CbCR Safe Harbour ====		==== Micro-step 2.2.3. - Transitional CbCR Safe Harbour ====
			After aggregation at Jurisdiction / JV-jursidiction level apply the

	De minimis test		De minimis test

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	==== Micro-step 2.2.4. - Transitional UTPR Safe Harbour ====		==== Micro-step 2.2.4. - Transitional UTPR Safe Harbour ====
			The TUT generated by the jurisidiction of the UPE does not contribute to the Total UTPR amount to be reallocated at the UTPR step

	=== Step 2.3. - Selection of the most pertinent Safe harbour mechanism ===		=== Step 2.3. - Selection of the most pertinent Safe harbour mechanism ===
			if any of the Transitional CbCR Safe Harbour are available, prioritize the one if the highest absolute value difference in percentage between the thresholds (or average of thresholds) to ensure the applicability of the Safe harbour.

			Apply then QDMTT Safe harbour

			And finaly Transitional UTPR Safe Harbour

			Permanent CbCR Safe harbour are not yet detailed

	=== Step 2.4. - Identification of MNE Groups in its initial phase of international activity ===		=== Step 2.4. - Identification of MNE Groups in its initial phase of international activity ===

Walid ELJAAFARI: /* Step 2.2. - Computation of the various available tests */

2023-12-31T08:14:39Z

Step 2.2. - Computation of the various available tests

← Older revision		Revision as of 08:14, 31 December 2023
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	=== Step 2.2. - Computation of the various available tests ===		=== Step 2.2. - Computation of the various available tests ===

	==== Micro-step 2.2.2. - Permanent Safe Harbour ====		==== Micro-step 2.2.1. - Permanent Safe Harbour ====
	De minimis test		De minimis test

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	Routine Profit test		Routine Profit test

	==== Micro-step 2.2.3. - QDMTT Safe Harbour ====		==== Micro-step 2.2.2. - QDMTT Safe Harbour ====

	==== Micro-step 2.2.4. - Transitional CbCR Safe Harbour ====		==== Micro-step 2.2.3. - Transitional CbCR Safe Harbour ====
	De minimis test		De minimis test

Walid ELJAAFARI: /* Step 2.3. - Selection of the best Safe harbour mechanisms */

2023-12-31T08:14:10Z

Step 2.3. - Selection of the best Safe harbour mechanisms

← Older revision		Revision as of 08:14, 31 December 2023
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	=== Step 2.2. - Computation of the various available tests ===		=== Step 2.2. - Computation of the various available tests ===

	~~==== Micro-step 2.2.1. - MNE Group in its initial phase of international activity ====~~

	==== Micro-step 2.2.2. - Permanent Safe Harbour ====		==== Micro-step 2.2.2. - Permanent Safe Harbour ====
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	==== Micro-step 2.2.4. - Transitional UTPR Safe Harbour ====		==== Micro-step 2.2.4. - Transitional UTPR Safe Harbour ====

	=== Step 2.3. - Selection of the ~~best~~ Safe harbour ~~mechanisms~~ ===		=== Step 2.3. - Selection of the most pertinent Safe harbour mechanism ===

			=== Step 2.4. - Identification of MNE Groups in its initial phase of international activity ===

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

Walid ELJAAFARI: /* Micro-step 2.2.2. - Transitional CbCR Safe Harbour */

2023-12-31T07:51:40Z

Micro-step 2.2.2. - Transitional CbCR Safe Harbour

← Older revision		Revision as of 07:51, 31 December 2023
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	Routine Profit test		Routine Profit test

	==== Micro-step 2.2.2. - Transitional CbCR Safe Harbour ====		==== Micro-step 2.2.3. - QDMTT Safe Harbour ====

			==== Micro-step 2.2.4. - Transitional CbCR Safe Harbour ====
	De minimis test		De minimis test

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	Routine Profit test		Routine Profit test

	Micro-step 2.2.4. - Transitional UTPR Safe Harbour		==== Micro-step 2.2.4. - Transitional UTPR Safe Harbour ====

	=== Step 2.3. - Selection of the best Safe harbour mechanisms ===		=== Step 2.3. - Selection of the best Safe harbour mechanisms ===

Walid ELJAAFARI: /* Step 2.2. - Computation of the various available tests */

2023-12-31T07:48:21Z

Step 2.2. - Computation of the various available tests

← Older revision		Revision as of 07:48, 31 December 2023
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	=== Step 2.2. - Computation of the various available tests ===		=== Step 2.2. - Computation of the various available tests ===

			==== Micro-step 2.2.1. - MNE Group in its initial phase of international activity ====

			==== Micro-step 2.2.2. - Permanent Safe Harbour ====
			De minimis test

			Simplified ETR test

			Routine Profit test

			==== Micro-step 2.2.2. - Transitional CbCR Safe Harbour ====
			De minimis test

			Simplified ETR test

			Routine Profit test

			Micro-step 2.2.4. - Transitional UTPR Safe Harbour

	=== Step 2.3. - Selection of the best Safe harbour mechanisms ===		=== Step 2.3. - Selection of the best Safe harbour mechanisms ===

Walid ELJAAFARI: /* Detailed Step by step approach */

2023-12-31T06:30:01Z

Detailed Step by step approach

← Older revision		Revision as of 06:30, 31 December 2023
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	== Detailed Step by step approach ==		== Detailed Step by step approach ==

	=== Step 2.1. - ~~Definition~~ of ~~Safe harbour perimeters~~ ===		=== Step 2.1. - Identification of the Non Material Constituent Entities ===

	=== Step 2.2. - ~~Application~~ of ~~Safe harbour elections~~ ===		=== Step 2.2. - Computation of the various available tests ===

	=== Step 2.3. - ===		=== Step 2.3. - Selection of the best Safe harbour mechanisms ===

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

Walid ELJAAFARI: /* Detailed Step by step approach */

2023-12-13T15:43:35Z

Detailed Step by step approach

← Older revision		Revision as of 15:43, 13 December 2023
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	=== Step 2.3. - ===		=== Step 2.3. - ===

			==== Purpose ====
			The purpose of the .

			==== General Logic ====
			This Step 1.2. will consist in .

			==== Data Input ====
			The Data input for Step 1.2. consists in :

			* The list of

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

			==== Data Output ====
			The Data output for Step 1.2. consists in :

			* The list of

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

			==== Detailed computations ====
			The list of Micro-Step is a follows :

			* Micro-Step 1.2.1.

			===== Micro-Step 1.2.1. Unknown subsidiaries =====
			This step .

			===== Micro-Step 1.2.2. Unknown parents =====
			This .

			===== Micro-Step 1.2.3. Entity absent from the shareholding structure =====
			This .

Walid ELJAAFARI: Title formatting

2023-12-12T11:09:26Z

Title formatting

← Older revision		Revision as of 11:09, 12 December 2023
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	=== Purpose ===		== Purpose ==
	The purpose of the Safe Harbour Analysis is to identify the Jurisdictions and Juridicition sub-perimeters that fall under Safe Harbour Provision and thus allow for an immediate nullification of the Top-Up Tax in the correspond Jurisidiction or Jurisdiction sub-perimeter, without having to provide the detailed information and or data required for the full Pillar 2 computation.		The purpose of the Safe Harbour Analysis is to identify the Jurisdictions and Juridicition sub-perimeters that fall under Safe Harbour Provision and thus allow for an immediate nullification of the Top-Up Tax in the correspond Jurisidiction or Jurisdiction sub-perimeter, without having to provide the detailed information and or data required for the full Pillar 2 computation.

	=== General Logic ===		== General Logic ==
	In order to perform the Safe Harbour Analysis, the set of elections made by the Filing Constituent Entity will be combined by the set of financial data provided to test the various Safe harbour mechanisms and assess whether any of them are applicable to the Juridiction or Juridiction/sub-perimeter under study. If several are applicable the algorithm will select preferably the provision of the transitional safe harbour requesting the simplest set of data, to allow for the continuation of the use of the Transitional Safe harbour rules, in the upcoming years.		In order to perform the Safe Harbour Analysis, the set of elections made by the Filing Constituent Entity will be combined by the set of financial data provided to test the various Safe harbour mechanisms and assess whether any of them are applicable to the Juridiction or Juridiction/sub-perimeter under study. If several are applicable the algorithm will select preferably the provision of the transitional safe harbour requesting the simplest set of data, to allow for the continuation of the use of the Transitional Safe harbour rules, in the upcoming years.

	=== Data Input ===		== Data Input ==
	The Data input for Macro-step 2 consists in :		The Data input for Macro-step 2 consists in :

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	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 2 consists in :		The Data output for Macro-step 2 consists in :

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	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]].

	=== Detailed Step by step approach ===		== Detailed Step by step approach ==

	==== Step 2.1. - Definition of Safe harbour perimeters ====		=== Step 2.1. - Definition of Safe harbour perimeters ===

	==== Step 2.2. - Application of Safe harbour elections ====		=== Step 2.2. - Application of Safe harbour elections ===

	==== Step 2.3. - ====		=== Step 2.3. - ===

Walid ELJAAFARI: /* Detailed Step by step approach */

2023-12-10T19:00:54Z

Detailed Step by step approach

← Older revision		Revision as of 19:00, 10 December 2023
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	=== Detailed Step by step approach ===		=== Detailed Step by step approach ===

	===== Step 2.1. - Definition of Safe harbour perimeters =====		==== Step 2.1. - Definition of Safe harbour perimeters ====

	===== Step 2.2. - Application of Safe harbour elections =====		==== Step 2.2. - Application of Safe harbour elections ====

	===== Step 2.3. - =====		==== Step 2.3. - ====

Walid ELJAAFARI: Creation

2023-12-10T16:20:49Z

Creation

New page

=== Purpose ===
The purpose of the Safe Harbour Analysis is to identify the Jurisdictions and Juridicition sub-perimeters that fall under Safe Harbour Provision and thus allow for an immediate nullification of the Top-Up Tax in the correspond Jurisidiction or Jurisdiction sub-perimeter, without having to provide the detailed information and or data required for the full Pillar 2 computation.

=== General Logic ===
In order to perform the Safe Harbour Analysis, the set of elections made by the Filing Constituent Entity will be combined by the set of financial data provided to test the various Safe harbour mechanisms and assess whether any of them are applicable to the Juridiction or Juridiction/sub-perimeter under study. If several are applicable the algorithm will select preferably the provision of the transitional safe harbour requesting the simplest set of data, to allow for the continuation of the use of the Transitional Safe harbour rules, in the upcoming years.

=== Data Input ===
The Data input for Macro-step 2 consists in :

* The list of Jurisdictions and Jurisdiction sub-perimeter derived from the Macro-step 1;
* The list of financial data aggregated at the right segmentation level for the relevant Safe Harbour;

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

=== Data Output ===
The Data output for Macro-step 2 consists in :

* The final list of Jurisdictions and Jurisdictions sub-perimeters falling under Safe-Harbour provisions and therefore with Top-Up Tax equal to 0;
* The final list of Jurisdictions and Jurisdictions sub-perimeters for which a detailed Pillar 2 and Top-Up Tax will need to be performed.

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

=== Detailed Step by step approach ===

===== Step 2.1. - Definition of Safe harbour perimeters =====

===== Step 2.2. - Application of Safe harbour elections =====

===== Step 2.3. - =====