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 2.2. - 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 2.2.3. - Transitional CbCR Safe Harbour

De minimis test

Simplified ETR test

Routine Profit test

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 .