Step-by-step computation for Macro-step 5: Difference between revisions
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== Purpose == | |||
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. | 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 == | |||
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. | 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 == | |||
The Data input for Macro-step 5 consists in : | The Data input for Macro-step 5 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 == | |||
The Data output for Macro-step 5 consists in : | The Data output for Macro-step 5 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 == | |||
=== Step 5.1. - Construction of Jurisdiction/Sub-group aggregates and indicators === | |||
=== Step 5.2. - GloBE Loss Deferred Tax computations === | |||
==== Step 5. | === Step 5.3. - Post-filing adjustments and recalculations === | ||
=== Step 5.4. - Application of De Minimis exclusion === | |||
=== Step 5.5. - Computation of Jurisdiction/Sub-group Top-Up Tax === | |||
=== Step 5.6. - Allocation of Top-Up Tax among LTCEs === | |||
Latest revision as of 06:52, 31 December 2023
Purpose
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
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
The Data input for Macro-step 5 consists in :
- The list of Jurisdictions and Jurisdiction sub-perimeters;
- The list of all the GloBE aggregates ;
The detailed matrix is available in the relevant section of the Pillar 2 Data Structure.
Data Output
The Data output for Macro-step 5 consists in :
- The Top-Up Tax for each Low Tax Constituent Entity ;
- The data required by the GIR to document the computation;
The detailed matrix is available in the relevant section of the Pillar 2 Data Structure.