Step-by-step computation for Macro-step 5

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.