Article 5.3. Substance-based Income Exclusion The policy rationale behind a formulaic, substance-based carve-out, based on payroll and tangible assets is to exclude a fixed return for substantive activities within a jurisdiction from the application of the GloBE Rules. The use of Payroll and Tangible Assets as indicators of substantive activities is justified because [...]
Article 5.2. Top-up Tax Article 5.2 sets out the rules for determining the amount of Top-up Tax that is due with respect to a jurisdiction and how such Top-up Tax is allocated amongst the LTCEs located in that jurisdiction. The rules in Article 5.2.1 first determine the Top-up Tax Percentage, which is the [...]
<< Go back to overview Next article>> Article 5.1. Determination of Effective Tax Rate The ETR computation in Article 5.1 is a central element of the GloBE Rules. It is used both to determine whether in a Fiscal Year, the MNE Group is subject to a minimum level of [...]
<< Go back to overview Next article>> Article 4.6. Post-filing Adjustments and Tax Rate Changes Article 4.6 governs adjustments to amounts of Covered Taxes incurred with respect to a jurisdiction after the GloBE Information Return for the period has been filed. An MNE Group’s liability for Covered Taxes may [...]
Article 4.5. - The GloBE Loss Election Article 4.5 provides an elective rule to effectively carry GloBE losses forward with a deemed deferred tax asset. When elected, Article 4.5 applies in lieu of the Article 4.4 modified deferred tax accounting rules. Accordingly, Article 4.5 is generally expected to be of greatest utility as [...]
Article 4.4. Mechanism to address temporary differences Article 4.4 provides the mechanism to address temporary differences, which arise when income or loss is recognised in a different year for financial accounting and tax. The principal mechanism that the GloBE Rules use to address temporary differences is set forth in Article 4.4 and builds [...]
<< Go back to overview Next article>> Article 4.3. Allocation of Covered Taxes from one Constituent Entity to another Constituent Entity The Tax allocation provisions in Chapter 4 follow the same pattern as the income allocation provisions. Covered Taxes are generally allocated to the Constituent Entity, including a Stateless [...]
<< Go back to overview Next article>> Article 4.2 Definition of Covered Taxes Article 4.2 sets out the definition of Covered Taxes that are taken into account in the determination of Adjusted Covered Taxes under Article 4.1. The definition of Covered Taxes is developed solely for the purposes of [...]
Article 4.1 Adjusted Covered Taxes The rules of Chapter 3 determine the GloBE Income or Loss for each Constituent Entity in the MNE Group. Chapter 4 contains the rules that determine the amount of taxes that are to be associated with that GloBE Income or Loss for purposes of calculating the ETR, which [...]
<< Go back to overview Next article>> Article 3.5 Allocation of Income or Loss from a Flow-through Entity Article 3.5 determines how the GloBE Income or Loss of a Flow-through Entity is allocated between different Constituent Entities. These rules are necessary because in many cases, these Entities would have [...]
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