Step-by-step computation for Macro-step 6

Purpose

The purpose of the Charging Mechanisms is to identify the amount of Top-Up Tax attributed to the parent entities of the Low Tax Constituent Entities according to the Income Inclusion Rule.

General Logic

In order to perform the computation, the different IPEs and POPEs and their Income Inclusion Ratios in their various subsidiaries are first computed. After this initial step, the exception to the IIR are identified along the shareholding chains, before computing the Allocable shares of Top-Up Tax of each Parent Entity still subject to the IIR in their LTCE subsiaries.

Data Input

The Data input for Macro-step consists in :

• The list of Top-Up Tax computed in Macro-step 5 for each LTCE's ;
• The Matrices of Indirect Ownership interests as well as Controlling Interest;

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 list of IPEs and POPEs subject to the IIR ;
• The amounts of Top-Up Tax due by these Parent entities;

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