Art. 3.2.3: transfer pricing

Example in para. 104.2 of Comm to Art. 3.2.3

Divergence between GloBE and accounting carrying values

Tangible asset carve-out under Substance-based Income Exclusion

Deferred tax liability (DTL) recapture rule

Paras. 112.1 to 112.6 of Comm to Art. 4.4.7 and Examples 4.4.7-1 to 3 in the June 2024 AG

Reversals allocated to pre-Transition Year DTLs

Unclaimed Accruals Annual Election

Exclusion of unclaimed DTL accruals

Outstanding Balance, Maximum Justifiable Amount, Unjustified Balance, Unjustified Balance (yearly movement)

FIFO methodology

Impact on Top-up Tax computations

Deferred tax liability (DTL) recapture rule

Paras. 90.22 & 90.23 of Comm to Art. 4.4.4 and Example 4.4.4-3 in the June 2024 AG

Outstanding Balance, Maximum Justifiable Amount, Unjustified Balance, Unjustified Balance (yearly movement)

LIFO methodology

Impact on Top-up Tax computations

Deferred tax liability (DTL) recapture rule

Paras. 90 to 90.11 of Comm to Art. 4.4.4 (amended / introduced by June 2024 AG)

General ledger (GL) accounts: (1) which are excluded from DTL recapture rule; or (2) which cannot be part of an Aggregate DTL Category

Hybrid Entity (defined in Art. 10.2.5)

No allocation of tax from Hybrid Entity owner to Hybrid Entity, for QDMTT purposes: para. 118-30 of Comm to Art. 10.1.1 definition of “QDMTT”

Corporate income tax imposed on Hybrid Entity owner generally does not qualify for that owner’s QDMTT purposes: paras. 118.28 & 118.29 of Comm to Art. 10.1.1 definition of “QDMTT”

Passive Income (defined in Art. 10.1.1)

Hybrid Entity

Allocation of tax from owner’s jurisdiction to Hybrid Entity’s jurisdiction

Simplified ETR computation under Transitional CbCR Safe Harbour

ETR computation under GloBE rules

Art. 4.3.2(d) & (e)

“Intragroup Financing Arrangement” (defined in Art. 10.1.1)

Art. 3.2.7 does not apply if lender is located in “Low-Tax Jurisdiction” and its Top-up Tax is significantly reduced by Substance-based Income Exclusion

Deferred tax liability (DTL) recapture rule

Paras. 90.30 & 90.31 of Comm to Art. 4.4.4 and Example 4.4.4-4 in the June 2024 AG

Reversals allocated to pre-Transition Year DTLs

Outstanding Balance, Maximum Justifiable Amount, Unjustified Balance, Unjustified Balance (yearly movement)

FIFO methodology

Impact on Top-up Tax computations

Deferred tax liability (DTL) recapture rule

Paras. 90.22 & 90.23 of Comm to Art. 4.4.4 and Example 4.4.4-2 in June 2024 AG

Outstanding Balance, Maximum Justifiable Amount, Unjustified Balance, Unjustified Balance (yearly movement)

FIFO methodology

Impact on Top-up Tax computations

Tangible asset carve-out in Substance-based Income Exclusion: impact of date on which assets acquired

For calendar year Fiscal Year, impact on tangible asset carve-out of asset acquisition on 1 December vs. 28 February

QDMTT

No allocation of CFC tax for QDMTT purposes, for either subsidiary’s computation or parent’s computation: paras. 118.28 & 118.30 of Comm to definition of “QDMTT” in Art. 10.1.1

Transfer pricing

Art. 3.2.3

Para. 99 of Comm to Art. 3.2.3

Art. 4.6.1

Bilateral APA

Material decrease in Covered Tax in a previous fiscal year

Additional Current Top-up Tax

Art. 5.4.1