Step-by-step computation for Macro-step 2

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. - 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

Micro-step 2.2.1. - Permanent Safe Harbour

De minimis test

Simplified ETR test

Routine Profit test

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

After aggregation at Jurisdiction / JV-jursidiction level apply the

De minimis test

Simplified ETR test

Routine Profit test

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

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

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 .