Jurisdictional Elections
Last updated on 2025-07-21
Overview
The Jurisdictional Elections workspace contains elections on the level of individual jurisdictions and on the level of reporting dimensions.
This article contains the following sections:
Navigation
The Jurisdictional Elections workspace can be found at Pillar 2 | Jurisdictional Elections. The workspace is displayed as follows, for example:
Configuring Jurisdictional Elections
To configure jurisdictional elections pursuant to the OECD model rules:
- Make sure the right period is selected in the Applies to period drop-down menu.
- Select a jurisdiction from the drop-down menu.
- Select a reporting dimension from the drop-down menu. For elections pertaining to a jurisdiction per se, select the default reporting dimension (“---”).
- Activate the applicable checkboxes in the categories Annual Elections, Five-year Elections, Safe Harbour Elections and Jurisdictional Exclusions, and Other elections (see also Election Categories below).
Notes:
- Some elections have a direct effect on the calculations in the Pillar 2 module, for example JE-10. Others, like JE-33, do not impact the calculations but must still be reported to the tax authorities if exercised.
- You can assess the effect of individual elections by creating one snapshot before activating the checkbox and another snapshot afterwards.
Election Categories
Annual elections only apply to the current reporting period and can be selected differently for every year.
Option
Description
JE-10
Aggregate Asset Gain Election (Article 3.2.6)
Activate this checkbox to include values stored at INC-2.16 and CT-2.12 in the CE calculation (C2) and in the jurisdictional blending (C4). Otherwise those values will be disregarded.
Note: This election has no effect on lines I-3 of the CE calculation and the jurisdictional blending. Gains and losses on immovable assets are always assessed at the CE level and aggregated and carried forward as part of the jurisdictional blending.
JE-12
Election not to apply the Substance-based Income Exclusion (Article 5.3.1)
Activate this checkbox if you want all data in CO-1.1 to CO-2.2 to be disregarded in the CE calculation and in the jurisdictional blending. Therefore, the carve-out amount in the CE calculation as well as the jurisdictional blending is set to zero.
JE-13
Negative Tax Expense Carry-forward
By default, excess negative tax expenses generated in case of a GloBE loss are recognized as part of the additional top-up tax amount (TT-2.2). Activate this checkbox to include that amount in the excess negative tax expense carry-forward (I-1.2) instead.
Note: The election has no effect on the negative tax expense amount (TCF-1.1) that is automatically generated if the negative tax expense exceeds the expected negative tax expense.
Note: JE-11 and JE-14 are only informational.
Five-year elections apply for the period of five years and cannot be changed within that period.
Option
Description
JE-31
Stock-based compensation election (Article 3.2.2)
Activate this checkbox to include values stored at INC-2.12 in the CE calculation and the jurisdictional blending. Otherwise those values will be disregarded.
JE-32
Realisation principle election (Article 3.2.5)
Activate this checkbox to include values stored at INC-2.15 in the CE calculation and the jurisdictional blending. Otherwise those values will be disregarded.
Note: JE-30 and JE-33 are only informational.
The elections in this passage will set the top-up tax of the jurisdiction to zero. This may be the case if the Safe Harbor Rules apply for a jurisdiction during the transition phase or when the De Minimis Exclusion is applicable.
Option
Description
JE-40
CbCR Transitional Safe Harbor
Activate this checkbox to set the top-up tax in the jurisdictional value to zero by adding a value in TT-3.1.
JE-41
Election to apply the de minimis exclusion for the Reporting Fiscal Year
Activate this checkbox to set the top-up tax in the jurisdictional value to zero by adding a value in TT-3.1.
Option
Description
JE-50
GloBE Loss Election (Article 4.5)
Activate this checkbox to set the total deferred tax adjustment amount and all data on deferred taxes and adjustments to zero, both in the CE calculation and the jurisdictional blending.
In case of an overall loss in the jurisdiction, activating this checkbox:
- Shows a GloBE loss carry-forward equal to the positive amount of the GloBE loss (I-2.2).
- Shows deferred tax income from the GloBE loss generated in the current period equal to the amount of the GloBE loss multiplied by the minimum tax rate of 15 % (GL-1.1).
- Adds the deferred tax income to the sum of the adjusted covered taxes instead of the total deferred tax adjustment amount in the jurisdictional blending.
In case of an overall GloBE income, activating this checkbox uses the GloBE loss carry-forward from prior periods (I-2.1) as deferred tax expense (GL-1.2) that lower the adjusted covered taxes of the jurisdiction. The deferred tax expense is the lesser amount of the GloBE income multiplied by the minimum tax rate and the GloBE loss carry-forward multiplied by the minimum tax rate.
In case of a GloBE loss carry-forward from prior periods, leaving JE-50 unchecked results in the loss carry-forward being fully used in the current period without regard to the GloBE Income.
Contains additional Pillar 2 information.
Option
Description
JE-60
Identification of subgroups (if any)
In this field, you can provide identifying information on subgroups such as joint ventures.