C2 – CE Calculations

Overview

In the Tax Compliance & Reporting solution, the C2 - CE Calculations workspace contains a list of the data points used in the Pillar 2 calculations, including entity elections as well as jurisdictional elections, to the extent that they impact individual CEs.

Values in this workspace might differ from the respective values in the entity data collection for any of the following reasons:

  • As in all parts of the Calculation section, values are displayed in the snapshot currency.
  • The entity data collection allows importing multiple values into the same field and making further adjustments in that line. The calculations use and display the Total value for each line item.
  • Activating the AMAE20 to AMAE26 checkboxes confers Excluded Entity status, effectively setting most values to zero. However, activating the checkbox for EE-4 strips an entity of that status.
  • Certain other elections also are included in the Pillar 2 calculations. Those elections are highlighted in the description of the linked item.

If a CE qualifies for the NMCE Safe Harbour, i.e. the NMCE Safe Harbour Check was successful and EE-1 has been activated for the CE (see Entity Election and General Information workspace in the OECD-Standard folder), the CE is excluded from the workspace.

The C2 – CE Calculations workspace can be found at Pillar 2 | Calculation | C2 – CE Calculations and is displayed as follows:

The 'C2 – CE Calculations' workspace is displayed. 'C2 – CE Calculations' workspace

The workspace contains two tabs:

  • C2 - CE Calculations: Displays the calculated values for each data point.

  • Additions / Reductions: Displays additions and reductions applied to the calculation.

To access this workspace and display the desired values:

Select a snapshot in the Home workspace.

Navigate to C2 – CE Calculations.

Select the jurisdiction or subgroup you want to review from the Jurisdiction drop-down list.

Notes on the Individual Sections
Determination of Net GloBE Income (Loss)
  • INC-1 and all following fields of this section: Excluded entity status sets this value to zero.
  • INC-2.11: Not selecting EE-2 sets this value to zero.
  • INC-2.12: Not selecting JE-31 sets this value to zero.
  • INC-2.13: This value reflects the sum of the relevant cross-border adjustments.
  • INC-2.15: Not selecting JE-32 sets this value to zero.
  • INC-2.16: Not selecting JE-10 sets this value to zero.
  • INC-2.17: This value reflects the sum of the relevant cross-border adjustments.
  • INC-2.18: Not selecting JE-33 sets this value to zero.
  • INC-2.24: Not selecting EE-8 sets this value to zero.
  • INC-2.25 represents the International Shipping Income Exclusion and equals the sum of SHIP-1 (International Shipping Income) and SHIP-2 (Qualified Ancillary International Shipping Income) from the International Shipping workspace (see also OECD-Standard). If the CE has no international shipping activities, this value will be zero.
  • INC-2 is the sum of adjustments: {INC-2.1}-{INC-2.2}-{INC-2.3}+{INC-2.4}-{INC-2.5}-{INC-2.6}+{INC-2.7}-{INC-2.8}-{INC-2.9}+{INC-2.10}-{INC-2.11}+{INC-2.12}-{INC-2.13}+{INC-2.14}+{INC-2.15}+{INC-2.16}+{INC-2.17}-{INC-2.18}-{INC-2.19}+{INC-2.20}-{INC-2.21}-{INC-2.22}-{INC-2.23}+{INC-2.24}-{INC-2.25}+{INC-2.26}
  • INC-3 is the Net GloBE Income (Loss): {INC-1}+{INC-2}
Determination of Covered Current Taxes
  • All fields except CT-2 and CT-3: Excluded entity status sets this value to zero. 
  • CT-2.6 includes covered taxes on income that is excluded from GloBE income, including taxes attributable to international shipping income (see SHIP-4 from the International Shipping workspace in the OECD-Standard folder). These covered taxes are subtracted from the current tax expense to maintain consistency between the income exclusion and the related tax treatment.
  • CT-2.12: Not selecting JE-10 sets this value to zero.
  • CT-2.16: Not selecting EE-8 sets this value to zero.
  • CT-2 is the sum of adjustments: {CT-2.1}+{CT-2.2}+{CT-2.3}+{CT-2.4}+{CT-2.5}-{CT-2.6}-{CT-2.7}-{CT-2.8}-{CT-2.9}-{CT-2.10}-{CT-2.11}-{CT-2.12}-{CT-2.13}-{CT-2.14}+{CT-2.15}+{CT-2.16} 
  • CT-3 is current taxes after adjustments: {CT-1}+{CT-2}
Determination of Covered Deferred Taxes
  • fields DT-1 to DT-16 and DT-4: 
    • Excluded entity status sets this value to zero. 
    • Selecting JE-50 sets this value to zero.
  • DT-1 is the Total Deferred Tax Expense calculated as: {DT-1.1} - {DT-1.2} + {DT-1.3}
  • DT-2 is the sum of adjustments: -{DT-2.1}-{DT-2.2}-{DT-2.3}-{DT-2.4}-{DT-2.5}-{DT-2.6}+{DT-2.7}+{DT-2.8}+{DT-2.9}-{DT-2.10}-{DT-2.11}-{DT-2.12}+{DT-2.13}-{DT-2.14}-{DT-2.15}+{DT-2.16}
  • DT-3 is the total deferred tax adjustment amount: {DT-1}+{DT-2}
  • DT-5 is the total deferred tax adjustment amount (recasted): {DT-3}-{DT-4}
  • ACT-1 are the Adjusted Covered Taxes: {CT-3}+{CT-4}+{DT-5}
Determination of Substance-based Income Exclusion Amount
  • fields CO-1, CO-1.1, CO-2, CO-2.2: 
    • Excluded entity status sets this value to zero. 
    • Selecting JE-12 sets this value to zero.
  • CO-1.1: States for each entity the Total value of eligible payroll costs from the entity data collection.
  • CO-1B: equals SHIP-3.1 from the International Shipping and represents the payroll costs related to employees engaged in international shipping activities. Because the related income is excluded from GloBE income (via INC-2.25), these payroll costs must also be excluded from the substance-based carve-out calculation to maintain consistency. This amount is subtracted from the eligible payroll costs before applying the carve-out percentage.
  • CO-1.2 shows the mark-up percentage relevant for eligible payroll costs according to the date in GEN-1.2.
  • CO-1 is the Payroll Carve-Out Amount: (({CO-1.1}+{CO-1A}-{CO-1B})*{CO-1.2})/100
  • CO-2.1:
    • States for each entity the Total value of the entity data collection in CO-2.1.
    • Is set to zero if the entity is an excluded entity, that did not elect not to be treated as an Excluded Entity (EE-4).
    • Is set to zero if the Entity elected not to apply the Substance-based Income Exclusion (JE-12)
  • CO-2B: equals SHIP-3.2 from the International Shipping workspace and represents the carrying value of tangible assets (e.g., ships, equipment) used in international shipping operations. Because the related income is excluded from GloBE income (via INC-2.25), these tangible assets must also be excluded from the substance-based carve-out calculation to maintain consistency. This amount is subtracted from the eligible tangible assets before applying the carve-out percentage.
  • CO-2.4 shows the mark-up percentage relevant for eligible tangible assets according to the date in GEN-1.2.
  • CO-2 is the Tangible Assets Carve-Out Amount: (({CO-2.3}+{CO-2A}-{CO-2B}) * {CO-2.4})/100
  • CO-3 is the Substance-based Income Exclusion: {CO-1}+{CO-2}

Note: The subtraction of CO-1B and CO-2B ensures that the substance-based income exclusion (carve-out) is calculated only on the payroll costs and tangible assets that relate to income that is included in the GloBE income calculation. This prevents double-counting of benefits when international shipping income is excluded.

Information for the Top-Up Tax Calculation and Information
  • fields TT-2.3, I-3: 
    • Excluded entity status sets this value to zero. 
    • I-3 is independent of the aggregate asset gain election (JE-10).
De Minimis Information

Option

Description


FYALL

Shows the number of fiscal years during the two preceding reporting periods during which the CE was not part of the calculation.


DM-4.1

Average of the revenue of the reporting fiscal year and the two preceding years if those are available. If fiscal years from earlier periods are not available, the value is calculated by dividing the cumulative revenue by the number of fiscal years available.


DM-4.2

Average of the GloBE revenue of the reporting fiscal year and the two preceding years if those are available. If fiscal years from earlier periods are not available, the value is calculated by dividing the cumulative GloBE revenue by the number of fiscal years available.


DM-4.3

Average of the financial accounting net income (or loss) of the reporting fiscal year and the two preceding years if those are available. If fiscal years from earlier periods are not available, the value is calculated by dividing the cumulative GloBE revenue by the number of fiscal years available.


DM-4.4

Average of the GloBE income (or loss) of the reporting fiscal year and the two preceding years if those are available. If fiscal years from earlier periods are not available, the value is calculated by dividing the cumulative GloBE income or loss by the number of fiscal years available. 


International Shipping Income Exclusion

Option

Description


SHIP-1.x

SHIP-1.1: Displays the categories selected in the entity data collection for international shipping activities pursuant to Article 3.3.2.

SHIP-1.2: The total revenue from international shipping activities, as entered in the entity data collection.

SHIP-1.3: The costs attributable to international shipping activities, as entered in the entity data collection.

SHIP-1: International Shipping Income, automatically calculated as the net income from international shipping activities ({SHIP-1.2} - {SHIP-1.3}). This amount contributes to the exclusion in INC-2.25.



SHIP-2.x

SHIP-2.1: Displays the categories selected in the entity data collection for qualified ancillary international shipping activities pursuant to Article 3.3.3. 

SHIP-2.2: The total revenue from qualified ancillary international shipping activities, as entered in the entity data collection.

SHIP-2.3: The costs attributable to qualified ancillary international shipping activities, as entered in the entity data collection.

SHIP-2: Qualified Ancillary International Shipping Income, automatically calculated as the net income from qualified ancillary activities ({SHIP-2.2} - {SHIP-2.3}). This amount contributes to the exclusion in INC-2.25.


SHIP-3.x

Adjustments to maintain consistency with income exclusion

SHIP-3.1: Displays the payroll costs related to international shipping activities, as entered in the entity data collection. This amount is subtracted in CO-1B when calculating the payroll carve-out amount (CO-1).

SHIP-3.2: Displays the carrying value of tangible assets used in international shipping operations, as entered in the entity data collection. This amount is subtracted in CO-2B when calculating the tangible assets carve-out amount (CO-2).

Covered Taxes: Taxes on excluded shipping income


SHIP-4

Displays the covered taxes related to the international shipping income that is being excluded, as entered in the entity data collection. This amount is included in CT-2.6 (Current tax expense on income excluded from GloBE Income or Loss) to ensure that taxes on excluded income are also removed from the covered taxes calculation.


Contact Us