C5 – Top-up Tax Allocation
Last updated on 2026-04-16
Overview
In the Tax Compliance & Reporting solution, the C5 – Top-up Tax Allocation workspace displays the top-up tax payable by low-taxed CEs and members of joint venture groups.
The tax is calculated by distributing the top-up tax amount per jurisdiction or subgroup to the low-taxed CEs with a positive GloBE income based on their share of the total GloBE income in that jurisdiction or subgroup.
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.
This article contains the following sections:
Navigation
The C5 – Top-up Tax Allocation workspace can be found at Pillar 2 | Calculation | C5 – Top-up Tax Allocation and is displayed as follows:
'C5 – Top-up Tax Allocation' workspace
To access this workspace and display the desired values:
Select a snapshot in the Home workspace.
Navigate to C5 – Top-up Tax Allocation.
Select the jurisdiction or subgroup you want to review from the Jurisdiction drop-down list.
Notes on the Individual Sections
Low-taxed CE Allocated Top-Up Tax
Field |
Description |
|---|---|
TA-1 |
ISO code of the jurisdiction or subgroup. |
TA-2.1 |
Positive GloBE income of the low-taxed CE or member of Joint Venture Group. |
TA-2.2 |
Total GloBE Income of the Jurisdiction or Subgroup. Equal to INC-3 of the entire jurisdiction or subgroup. |
TA-2 |
Relevant Percentage of the Net GloBE Income: {TA-2.1} / {TA-2.2} * 100. |
TA-3.1 |
Total Top-Up Tax Amount of the Jurisdiction or Subgroup. Equal to TT-3. |
TA-3 |
Top-Up Tax Amount of the low-taxed CE or member of Joint Venture Group: {TA-2} * {TA-3.1} / 100. |
Income Inclusion Rule
Field |
Description |
|---|---|
TA-4.1 |
Inclusion of Top-up Tax Expense of subsidiaries. Equal to the Total amount in IR-1. |
TA-4.2 |
Income Inclusion Rule Offset: {TA-3} * {TA-4.1} / 100. |
TA-5 |
Allocation of Top-up Tax Amount to local CE under a QDMTT. |
Additional Current Top-up Tax
Field |
Description |
|---|---|
TA-6.1 |
Total Amount of Additional Current Top-up Tax of the Jurisdiction or Subgroup. |
TA-6.2 |
Allocation Basis. |
TA-6.3 |
Allocation Rate. |
TA-6 |
Additional Current Top-up Tax allocated to CE or member of Joint Venture Group. |
TA-7 |
Additional Current Top-up Tax Expense of CE or member of Joint Venture Group. |