Step-by-step computation for Macro-step 7 - Revision history

Walid ELJAAFARI: /* Micro-Step 7.1.2. Application of the Transitional UTPR Safe harbor */

2023-12-31T07:07:17Z

Micro-Step 7.1.2. Application of the Transitional UTPR Safe harbor

← Older revision		Revision as of 07:07, 31 December 2023
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	===== Micro-Step 7.1.2. Application of the Transitional UTPR Safe harbor =====		===== Micro-Step 7.1.2. Application of the Transitional UTPR Safe harbor =====
	This step allows to exclude the UPEs Jurisdiction from the UTPR computation if the nominal tax rate of the jurisdiction is higher than 20% during the transition period.		This step allows to exclude the UPEs Jurisdiction from the UTPR computation if the nominal tax rate of the jurisdiction is higher than 20% during the transition period.

			The contribution to the total UTPR Amount thus does not take into account the contribution of eventual Top-Up Tax from LTCE's within the Reference Jurisdiction.
	===== Micro-Step 7.1.3. Complete reduction to 0 for LTCEs for which UPEs ownership interests are fully covered by IIR =====		===== Micro-Step 7.1.3. Complete reduction to 0 for LTCEs for which UPEs ownership interests are fully covered by IIR =====
	This step requires to reduce the contribution to the Total UTPR Top-Up Tax Amount of a given LTCE to 0 if the UPEs direct or indirect ownership interests are held directly or indirectly by Parent Entities having to apply an IIR.		This step requires to reduce the contribution to the Total UTPR Top-Up Tax Amount of a given LTCE to 0 if the UPEs direct or indirect ownership interests are held directly or indirectly by Parent Entities having to apply an IIR.

Walid ELJAAFARI at 06:30, 14 December 2023

2023-12-14T06:30:21Z

← Older revision		Revision as of 06:30, 14 December 2023
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	* The list of allocated Top-Up Tax amounts according to the IIR;		* The list of allocated Top-Up Tax amounts according to the IIR;
	* The input data for the formulary apportionment;		* The input data for the formulary apportionment;
	* The ~~share of~~ UTPR ~~effectively charged in the previous years~~;		* The Financial data for UTPR computations;
			* Article 9.3. Characteristics;

	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 Allocable Share Matrix		* The Allocable Share Matrix
	* The Indirect Ownership Interest Matrix		* The Indirect Ownership Interest Matrix
			* The Article 9.3. Characteristics;
			* The Macro-Step 2 results on Safe harbor and the nominal tax rate of the UPEs jurisdiction

	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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	As the treatments of the following steps are counted as reductions of this total we will define them as such.		As the treatments of the following steps are counted as reductions of this total we will define them as such.

	===== Micro-Step 7.1.2. Complete reduction to 0 for LTCEs for which UPEs ownership interests are fully covered by IIR =====		No value is generated at this stage for a group corresponding to the article 9.3. criterion.
			===== Micro-Step 7.1.2. Application of the Transitional UTPR Safe harbor =====
			This step allows to exclude the UPEs Jurisdiction from the UTPR computation if the nominal tax rate of the jurisdiction is higher than 20% during the transition period.
			===== Micro-Step 7.1.3. Complete reduction to 0 for LTCEs for which UPEs ownership interests are fully covered by IIR =====
	This step requires to reduce the contribution to the Total UTPR Top-Up Tax Amount of a given LTCE to 0 if the UPEs direct or indirect ownership interests are held directly or indirectly by Parent Entities having to apply an IIR.		This step requires to reduce the contribution to the Total UTPR Top-Up Tax Amount of a given LTCE to 0 if the UPEs direct or indirect ownership interests are held directly or indirectly by Parent Entities having to apply an IIR.

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	In this case we can add a reduction to the Total UTPR Amount for the LTCE j equal to the Top-Up Tax it was allocated.		In this case we can add a reduction to the Total UTPR Amount for the LTCE j equal to the Top-Up Tax it was allocated.

	===== Micro-Step 7.1.3. Final reduction by the Top-Up Tax covered by the IIR =====		===== Micro-Step 7.1.4. Final reduction by the Top-Up Tax covered by the IIR =====
	This step is more restrictive as it allows for a smaller reduction to the UTPR Top-Up Tax that only corresponds to the Top-Up Tax Amounts effectively brought to charge.		This step is more restrictive as it allows for a smaller reduction to the UTPR Top-Up Tax that only corresponds to the Top-Up Tax Amounts effectively brought to charge.

	Thus for a LTCE j for which no reduction has been recorded at step 7.1.2. the following reduction is computed: <small>Sum<sub>k parent of j</sub> (AllocableShareWithOffset(k, j))</small>		Thus for a LTCE j for which no reduction has been recorded at step 7.1.2. the following reduction is computed: <small>Sum<sub>k parent of j</sub> (AllocableShareWithOffset(k, j))</small>
	~~===== Micro-Step 7.1.4. Application of the Transitional UTPR Safe harbor =====~~
	~~This step allows to further the reduction by .~~
	=== Step 7.2. - UTPR computation per jurisdiction ===		=== Step 7.2. - UTPR computation per jurisdiction ===

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	==== General Logic ====		==== General Logic ====
	This Step 1.2. will consist in the allocation the Total UTPR Top-Up Tax Amount based on a formulary apportionment key using the number of employees and the net book value of tangible assets in these jurisdiction .		This Step 7.2. will consist in the allocation the Total UTPR Top-Up Tax Amount based on a formulary apportionment key using the number of employees and the net book value of tangible assets in these jurisdiction .

	==== Data Input ====		==== Data Input ====
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	* The Remaining Total UTPR Top-Up Tax Amount after Step 7.1.		* The Remaining Total UTPR Top-Up Tax Amount after Step 7.1.
			* The UTPR Top-up Tax carryforward and Additional cash tax expense incurred by CEs in UTPR jurisdiction
	* The Number of employees (preferably at CE level)		* The Number of employees (preferably at CE level)
	* The Tangible Assets (preferably at CE level)		* The Tangible Assets (preferably at CE level)
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	==== Data Output ====		==== Data Output ====
	The Data output for Step 1.2. consists in :		The Data output for Step 7.2. consists in :

	* The list of		* UTPR Top-up tax percentage and amount allocated to each jurisdiction
			* The list of UTPR Top-up tax left to be carried forward in each jurisdiction

	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 list of Micro-Step is a follows :		The list of Micro-Step is a follows :

	* Micro-Step 1.2.1.		* Micro-Step 7.2.1. Definition of UTPR jurisdiction coefficients
			* Micro-Step 7.2.2. Computation of the UTPR per jurisdiction
			* Micro-Step 7.2.3. Computation of the UTPR Top-up tax left to be carried forward

	===== Micro-Step 1.2.1. ~~Unknown subsidiaries~~ =====		===== Micro-Step 7.2.1. Definition of UTPR jurisdiction coefficients =====
	~~This step .~~		Let's consider that for all jurisdictions of the concerned entities we have:

	~~===== Micro~~-~~Step 1~~.2.2. ~~Unknown parents ====~~=		* A [[boolean]] indicating the existence of a UTPR rule in jurisdiction j: IS_UTPRj.
	~~This~~ .		* The number of employees in jurisdiction j, excluding Invesment entities and remaining in Flow-through: FTEj.
			* The total amount of tangible assets in jurisdiction j, excluding Invesment entities and remaining in Flow-through: TAj.
			* A boolean indicating whether the UTPR for the past year was actually levied. For a jurisdiction j, let UTPRPYj be a variable:
			** Equal to 1 if UTPR Top-up Tax carryforward(j)=0 and 0 otherwise.
			** Forced to 1 for all j, if the initial sum of UTPRPYj across all j equals 0.

	===== Micro-Step 1.2.3. ~~Entity absent from~~ the ~~shareholding structure~~ =====		Then for a given jurisdiction j,
	~~This .~~
			<small>coefUTPRj = 50% x UTPRPYj x IS_UTPRj x FTEj / Sum<sub>all k</sub> (UTPRPYk x IS_UTPRk x FTEk) + 50% x UTPRPYj x IS_UTPRj x TAj / Sum<sub>all k</sub> (UTPRPYk x IS_UTPRk x TAk).</small>

			===== Micro-Step 7.2.2. Computation of the UTPR per jurisdiction =====
			Thus, for Jurisdiction j, Share of UTPR(j) = coefUTPRj x Remaining Total UTPR Top-Up Tax Amount.

			===== Micro-Step 7.2.3. Computation of the UTPR Top-up tax left to be carried forward =====
			And finally :

			<small>UTPR Top-up tax left to be carried forward (j) = Share of UTPR(j) - Additional cash tax expense incurred by CEs in UTPR jurisdiction j</small>

Walid ELJAAFARI: /* Step 7.1. - Computation of the UTPR Top-Up Tax amount */

2023-12-14T06:04:35Z

Step 7.1. - Computation of the UTPR Top-Up Tax amount

@@ Line 25: / Line 25: @@
 == Detailed Step by step approach ==
-=== Step 7.1. - Computation of Total UTPR amount ===
+=== Step 7.1. - Computation of the UTPR Top-Up Tax amount ===
-=== Step 7.2. - Computation of coefficients per Jurisdictions ===
+==== Purpose ====
-=== Step 7.3. - Final UTPR computation per jurisdiction ===
+Thus for a LTCE j for which no reduction has been recorded at step 7.1.2. the following reduction is computed: <small>Sum<sub>k parent of j</sub> (AllocableShareWithOffset(k, j))</small>
 ==== Purpose ====
-The purpose of the .
+The purpose of this step is to allocate the Total UTPR Top-Up Tax Amount computed at the previous step between the jurisdictions that have a qualified UTPR in place based on a formulary apportionment key using the number of employees and the tangible assets in these jurisdiction.
 ==== General Logic ====
-This Step 1.2. will consist in .
+This Step 1.2. will consist in the allocation the Total UTPR Top-Up Tax Amount based on a formulary apportionment key using the number of employees and the net book value of tangible assets in these jurisdiction .
 ==== Data Input ====
 The Data input for Step 1.2. consists in :
-* The list of
+* The Remaining Total UTPR Top-Up Tax Amount after Step 7.1.
 The detailed matrix is available in the relevant section of the [[Pillar 2 Data Structure]].

Walid ELJAAFARI: /* Step 7.1. - Computation of Total UTPR amount */

2023-12-13T22:16:43Z

Step 7.1. - Computation of Total UTPR amount

← Older revision		Revision as of 22:16, 13 December 2023
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	=== Step 7.3. - Final UTPR computation per jurisdiction ===		=== Step 7.3. - Final UTPR computation per jurisdiction ===

			==== 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

2023-12-12T11:11:49Z

Title formatting

← Older revision		Revision as of 11:11, 12 December 2023
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	=== Purpose ===		== Purpose ==
	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.		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 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.		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 7 consists in :		The Data input for Macro-step 7 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 consists in :		The Data output for Macro-step 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 7.1. - Computation of Total UTPR amount ====		=== Step 7.1. - Computation of Total UTPR amount ===

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

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

Walid ELJAAFARI: Creation

2023-12-10T19:14:50Z

Creation

New page

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

* The list of Top-Up Tax amounts from the Macro-step 5 ;
* 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]].

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

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

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

=== Detailed Step by step approach ===

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

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

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