Model Rules – Article 3.5


<< 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 [...]

Model Rules – Article 3.52023-08-11T11:37:09+02:00

Model Rules – Article 3.2


Article 3.2 - Adjustments to determine GloBE Income or Loss Once the Financial Accounting Net Income or Loss of a Constituent Entity is determined, it is adjusted for certain book to tax differences (that is, differences between financial accounting results and taxable income results) that are common in Inclusive Framework jurisdictions. Differences between [...]

Model Rules – Article 3.22023-08-12T13:53:16+02:00

Model Rules – Article 2.6


<< Go back to overview Next article>> Article 2.6 Allocation of Top-Up Tax for the UTPR Articles 2.6.1 to 2.6.3 describe the formula used to allocate the Total UTPR Top-up Tax Amount to each UTPR Jurisdiction on the basis of a substance-based allocation key. 2.6.1.Subject to Articles 2.6.2 [...]

Model Rules – Article 2.62023-08-11T11:26:21+02:00

Model Rules – Article 1.2


<< Go back to overview Next article>> Article 1.2 MNE Group and Group Article 1.2 defines the terms “MNE Group” and “Group” for the purposes of the GloBE Rules. These terms, which are used to determine the scope of the GloBE Rules under Article 1.1, perform two key functions. [...]

Model Rules – Article 1.22023-08-11T17:46:12+02:00

Model Rules – Article 1.3


<< Go back to overview Next article>> Article 1.3 Constituent Entity The term Constituent Entity defines those Group Entities that are subject to the GloBE Rules. For example, a Group Entity must be a Constituent Entity before it can be treated as an LTCE and subject to charge under [...]

Model Rules – Article 1.32023-08-11T11:34:11+02:00

Model Rules – Article 1.4


<< Go back to overview Next article>> Article 1.4 Ultimate Parent Entity The definition of UPE is set out in Article 1.4. The UPE definition is used as part of the definition of Group and is the starting point for identifying all the Entities that comprise the MNE Group. [...]

Model Rules – Article 1.42023-08-11T17:43:41+02:00

Model Rules – Article 1.5


<< Go back to overview Next article>> Article 1.5 Excluded Entity Article 1.5 specifies those Entities that are Excluded Entities and therefore not subject to the GloBE Rules. Qualification as an Excluded Entity has three practical effects under the GloBE Rules: a) First, the IIR and UTPR do not [...]

Model Rules – Article 1.52023-08-11T17:56:26+02:00

Model Rules – Article 1.1


Article 1.1 Scope Article 1.1 limits the application of the GloBE Rules to MNE Groups whose annual consolidated revenues in at least two of the four preceding Fiscal Years equal or exceed EUR 750 million. These scope rules ensure that smaller Groups and purely domestic Groups remain unaffected by the GloBE Rules. The [...]

Model Rules – Article 1.12023-08-12T20:10:31+02:00
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