Commission Implementing Regulation (EU) 2015/2378 of 15 December 2015 laying down detailed rules for implementing certain provisions of Council Directive 2011/16/EU on administrative cooperation in the field of taxation and repealing Implementing Regulation (EU) No 1156/2012

The information in the message header identifies the tax administration that is sending the DPI message. It specifies when the message was created, what reporting period the report is for, and the nature of the report (original, supplemental, etc.).

The DPI Body element contains the information on the Reporting Platform Operator, as well as on the Relevant Services performed by Reportable Sellers that give rise to the exchange.

The DPI Version.

ANNEX XV

List referred to in Article 2d

The statistical data required for the mandatory exchange of information in accordance with Article 8ac(2) of Directive 2011/16/EU, pursuant to Article 23(4) of that Directive covers the following information:

• — Per message, statistics on the total number of reports received from reporting platform operators for the mandatory automatic exchange of information

• — Per message, statistics on the total number of reports received from each other Member State

• — Per reportable seller, statistics on reportable seller type, taxpayer identification number or functional equivalent, Member State of residence of reportable seller and reason for exchange; Member State of residence of reportable seller and/or Member State in which the immovable property is located

• — Per reporting platform operator, statistics on relevant activity type and consideration and type of property listing.

ANNEX XVI

Form referred to in Article 2f(1)

The form to be used for the communication of information on Excluded Platform Operators pursuant to Article 8ac(6) of Directive 2011/16/EU and for the communication of information on Foreign Platform Operators pursuant to subparagraph F(2) and F(4) of Section IV of Annex V to Directive 2011/16/EU contains the following fields:

• (a) Name of Excluded Platform Operator

• (b) postal address of Excluded Platform Operator

• (c) electronic address, including websites of Excluded Platform Operator

• (d) any TIN issued to the Excluded Platform Operator, if available

• (e) Member State where the demonstration in accordance with subparagraph A(3) of Section I of Annex V to Directive 2011/16/EU was provided to,; and

• (f) fiscal year from which the status of Excluded Platform Operator was granted.

Format of the individual identification number for Foreign Platform Operators

The individual identification number shall be composed of the following 12-digit format, CCYYYYXXXXXX where: CC is the ISO Country Code of the Member State issuing the individual identification number; YYYY is the year where the Foreign Platform Operator registers with the Member State of single registration; and XXXXXX is a unique string of characters composed of letters and/or numbers.

Retention period for certain information deleted or removed from the central register

• 1.Where the registration of a Reporting Platform Operator within the meaning of point (b) of subparagraph A(4) of Section I of Annex V to Directive 2011/16/EU, as amended by Directive (EU) 2021/514 is revoked in accordance with subparagraph F(7) of Section IV of Annex V to Directive 2011/16/EU, the Member State of single registration shall delete the Reporting Platform Operator from the central register. The central register shall retain the deleted information referred to in subparagraph F(2) and F(4) of Section IV of Annex V to Directive 2011/16/EU for no longer than 12 months from the date of deletion.

• 2.Information recorded in the central register for Excluded Platform Operators will be removed where an Excluded Platform Operator within the meaning of subparagraph A(3) of Section I of Annex V to Directive 2011/16/EU as amended by Directive (EU) 2021/514 does not demonstrate, upfront and on an annual basis, to the satisfaction of the competent authority of the Member State to which, in accordance with the rules laid down in subparagraphs A(1) to A(3) of Section III of Annex V to Directive 2011/16/EU, the Platform Operator otherwise would have had to report that Platform’s entire business model is such that it does not have Reportable Sellers. The central register shall retain the removed information referred to in Annex XVI, points (a) to (f) of this Regulation for no longer than 12 months from the date of the removal of the recorded information.

ANNEX XVII

Computerised format to be used for the mandatory automatic exchange of information pursuant to Article 8ae(5)

http://www.w3.org/2001/XMLSchema" xmlns:stf="urn:oecd:ties:globestf:v5" xmlns:iso="urn:oecd:ties:isoglobetypes:v1" targetNamespace="urn:oecd:ties:globe:v2" elementFormDefault="qualified" attributeFormDefault="unqualified" version="1.0">

Message type defines the type of reporting

The MessageTypeIndic defines the type of message sent

The message contains new information

The message contains corrections for previously sent information

The message advises there is no data to report

ID Type – Rules

QIIR applicable to Low-Taxed Constituent Entities located in other jurisdictions only

QIIR applicable to both Low-Taxed Constituent Entities located in other jurisdictions and in the jurisdiction of the Parent Entity

QUTPR

QDMTT

Not applicable

ID Type – GloBEStatus

Constituent Entity

Flow-Through Entity – Tax Transparent

Flow-Through Entity – Reverse Hybrid

Hybrid Entity

Permanent Establishment

Main Entity

Minority-Owned Parent Entity

Minority-Owned Subsidiary

Minority-Owned Constituent Entity

Investment Entity

Insurance Investment Entity

Securitisation Entity

JV

JV Subsidiary

Non-Material Constituent Entity

Excluded Entity

Parent Entity required to apply a QIIR under Article 10.3.5

Non-group Member

FilingInfo – FilingCE – Role

Ultimate Parent Entity

Designated Filing Entity

Designated Local Entity

Constituent Entity

Other

FilingInfo – AccountingInfo – CFsofUPE

Subparagraph a

Subparagraph b

Subparagraph c

Subparagraph d

Excluded Entity – Type

Governmental Entity

International Organisation

Non-profit Organisation

Pension Fund

Investment Fund that is an UPE

Real Estate Investment Vehicle that is an UPE

Subgroup – TypeofSubGroup

Constituent Entity

Flow-Through Entity – Tax Transparent

Flow-Through Entity – Reverse Hybrid

Hybrid Entity

Permanent Establishment

Main Entity

Minority-Owned Parent Entity

Minority-Owned Subsidiary

Minority-Owned Constituent Entity

Investment Entity

Insurance Investment Entity

Securitisation Entity

JV

JV Subsidiary

Non-Material Constituent Entity

POPE

Intermediate Parent Entity

Ultimate Parent Entity

Excluded Entity

Parent Entity required to apply a QIIR under Art. 10.3.5

Non-Group member

Ownership Type

UPE

Constituent Entities

JVs

JV Subsidiaries

Excluded Entities (aggregate)

Non-Group members (aggregate)

POPE IPE

POPE

Intermediate Parent Entity

Parent Entity required to apply a QIIR under Art. 10.3.5

Excluded Entity – Type

Governmental Entity

International Organisation

Non-profit Organisation

Pension Fund

Investment Fund that is an UPE

Real Estate Investment Vehicle that is an UPE

Entity owned by Excluded Entities under Article 1.5.2(a)

Entity owned by Excluded Entities under Article 1.5.2(b)

Type of Subgroup

Constituent Entities

Minority-Owned Subgroup

Standalone MOCEs

Investment Entities

JV Group

Stateless Constituent Entity

Summary – SafeHarbour

De minimis Exclusion

QDMTT safe harbour

Transitional CbCR Safe Harbour – De minimis test

Transitional CbCR Safe Harbour – ETR test

Transitional CbCR Safe Harbour – Routine profit test

Transitional UTPR Safe Harbour

Permanent Safe Harbour – De minimis test

Permanent Safe Harbour – ETR test

Permanent Safe Harbour – Routine profit test

Summary – ETR Range

below 2.5%

2.5% or above but below 5%

5% or above but below 7.5%

7.5% or above but below 10%

10% or above but below 12.5%

12.5% or above but below 15%

15% or above but below 17.5%

17.5% or above but below 20%

20% or above but below 22.5%

22.5% or above but below 25%

25% or above but below 27.5%

27.5% or above but below 30%

30% or above

Section 3.2 not completed

QDMTTTut

No Top-up Tax payable

below EUR 1 million

EUR 1 million to below EUR 5 million

EUR 5 million to below EUR 25 million

EUR 25 million to below EUR 50 million

EUR 50 million to below EUR 75 million

EUR 75 million to below EUR 100 million

EUR 100 million to below EUR 250 million

EUR 250 million or above

Globe TuT

No Top-up Tax payable

below EUR 1 million

EUR 1 million to below EUR 5 million

EUR 5 million to below EUR 25 million

EUR 25 million to below EUR 50 million

EUR 50 million to below EUR 75 million

EUR 75 million to below EUR 100 million

EUR 100 million to below EUR 250 million

EUR 250 million or above

Type of SubGroup

Constituent Entities

Minority-Owned Subgroup

Standalone MOCEs

Investment Entities

JV Group

Stateless Constituent Entity

Transitional CbCR Safe Harbour-Constituent Entities

Transitional CbCR Safe Harbour- JV Group (specify which JV Group)

Transitional UTPR Safe Harbour

MainEntityPEandFTEBasis

Article 3.4

Article 3.5.3

Article 3.5.1(a)

Article 3.5.1(b)

Cross Border Adjustments

Article 3.2.3

Article 3.2.7

UPE Adjustment Basis

Article 7.1.1 (a)(i)

Article 7.1.1 (a)(ii)

Article 7.1.1 (b)

Article 7.1.1 (c)

Article 7.2.1 (a)(i)

Article 7.2.1 (a)(ii)

Article 7.2.1 (a)(iii)

Article 7.2.1 (b)

Article 7.2.1 (c)

Article 7.2.2

3.2.1.1 Computation of GloBE Income (Loss)

Net Taxes Expense – Article 3.2.1 (a)

Excluded Dividends – Article 3.2.1 (b)

Excluded Equity Gain or Loss – Article 3.2.1 (c)

Included Revaluation Method Gain or Loss – Article 3.2.1 (d)

Gain or loss from disposition of assets and liabilities excluded under Article 6.3 – Article 3.2.1 (e)

Asymmetric Foreign Currency Gains or Losses – Article 3.2.1 (f)

Policy Disallowed Expenses – Article 3.2.1 (g)

Prior Period Errors – Article 3.2.1 (h)

Changes in Accounting Principles – Article 3.2.1 (h)

Accrued Pension Expense – Article 3.2.1 (i)

Debt releases – Article 3.2.1

Stock-based compensation – Article 3.2.2

Arm’s length adjustments – Article 3.2.3

Qualified Refundable Tax Credit or Marketable Transferable Tax Credit – Article 3.2.4

Election for Gains and losses using realisation principle – Article 3.2.5

Election for Adjusted Asset Gain – Article 3.2.6

Intragroup Financing Arrangement expense – Article 3.2.7

Election for intragroup transactions in same jurisdiction – Article 3.2.8

Insurance company taxes charged to policyholders – Article 3.2.9

Increase/decrease to equity attributed to Additional Tier One and Restricted Tier One Capital distributions paid/payable or received/receivable – Article 3.2.10

Constituent Entities joining and leaving an MNE Group – Article 3.2.11 and 6.2

Reduction of GloBE Income of the UPE that is a Flow-through Entity – Article 3.2.11 and 7.1

Reduction of GloBE Income of the UPE that is subject to a Deductible Dividend Regime – Article 3.2.11 and 7.2

Taxable Distribution Method election – Article 3.2.11 and 7.6

International Shipping Income – Article 3.3

Transactions between Constituent Entities – Article 9.1.3

International Shipping Category

Article 3.3.2.a

Article 3.3.2.b

Article 3.3.2.c

Article 3.3.2.d

Article 3.3.2.e

Article 3.3.2.f

Qualified Ancillary Shipping Income

Article 3.3.3.a

Article 3.3.3.b

Article 3.3.3.c

Article 3.3.3.d

Article 3.3.3.e

Adjusted Basis

Article 4.3.2 (a)

Article 4.3.2 (b)

Article 4.3.2 (c)

Article 4.3.2 (d)

Article 4.3.2 (e)

Article 4.3.3 (a)

Article 4.3.3 (b)

Article 4.3.4

Article 4.3.2(c) – Blended CFC regime

3.2.1.2 Computation of Adjusted Covered Taxes

Covered Tax accrued as an expense in the profit before taxation in the financial accounts – Article 4.1.2 (a)

Covered Taxes for uncertain tax position recorded as a reduction to Covered Taxes in prior year – Article 4.1.2 (c)

Qualified Refundable Tax Credit or Marketable Transferable Tax Credits recorded as a reduction to current tax expense – Article 4.1.2 (d)

Qualified Flow-through Tax Benefits of Qualified Ownership Interests – Article 3.2.1 (c)

Current tax expense on income excluded from GloBE Income or Loss – Article 4.1.3 (a)

Non-Qualified Refundable Tax Credit, Non-Marketable Transferable Tax Credit or Other Tax Credits not recorded as a reduction to current tax expense – Article 4.1.3 (b)

Covered Taxes refunded or credited (except for any Qualified Refundable Tax Credit, or Marketable Transferable Tax Credits) not treated as an adjustment to current tax expense – Article 4.1.3 (c)

Current tax expense related to uncertain tax position– Article 4.1.3 (d)

Current tax expense not expected to be paid within three years – Article 4.1.3 (e)

Post-filing adjustments – Article 4.6.1.

Covered Taxes relating to Net Asset Gain or Net Asset Loss – Article 3.2.6

Reduction of Covered Taxes of the UPE that is a Flow-through Entity – Article 7.1

Covered Taxes for GloBE Income of the UPE that is reduced under a Deductible Dividend Regime – Article 7.2.2

Deemed Distribution Tax – Article 7.3

Taxable Distribution Method election – Article 7.6 (b)

Total Deferred Tax Adjustment Amount – Article 4.4.1(b)

Increase or decrease in Covered Taxes recorded in equity or Other Comprehensive Income relating to amounts included in GloBE Income or Loss that will be subject to tax under local tax rules – Article 4.1.1 (c)

3.2.2 Jurisdictional computations relating to deferred tax accounting

Deferred tax expense related to items excluded from GloBE Income or Loss – Article 4.4.1 (a)

Deferred tax expense related to Disallowed Accruals– Article 4.4.1 (b)

Deferred tax expense related to Unclaimed Accruals – Article 4.4.1 (b)

Valuation adjustment or accounting recognition adjustment related to a deferred tax asset – Article 4.4.1 (c)

Deferred tax expense arising from a re-measurement related to changes in the tax rate – Article 4.4.1 (d)

Deferred tax expense related to the generation and use of tax credits – Article 4.4.1 (e)

Substitute Loss Carry Forward DTA or deemed Substitute Loss Carry Forward DTA – Article 4.4.1 (e)

Disallowed Accruals or Unclaimed Accruals paid during the fiscal year – Article 4.4.2 (a)

Recapture Deferred Tax Liability paid during the fiscal year– Article 4.4.2 (b)

Recognition of a loss Deferred Tax Asset not included in the financials – Article 4.4.2 (c)

Deferred tax expense adjustment resulting from a reduction to a tax rate – Article 4.6.2

Deferred tax expense adjustment resulting from an increase to a tax rate – Article 4.6.3

Constituent Entities joining and leaving an MNE Group – Article 6.2

Deferred tax expense of the UPE that is a Flow-through Entity – Article 7.1

Deferred tax expense of the UPE that is subject to Deductible Dividend Regime – Article 7.2

Deferred tax adjustment resulting from transactions between Constituent Entities – Article 9.1.3

3.2.2 Jurisdictional computations relating to deferred tax accounting

Article 3.2.6

Article 4.4.4

Article 4.6.1

Article 4.6.4

Article 7.3.5

Article 7.3.7

3.2.1.2 Computation of Adjusted Covered Taxes

Covered Tax accrued as an expense in the profit before taxation in the financial accounts – Article 4.1.2 (a)

GloBE Loss Deferred Tax Asset established under Article 4.5.1 or used – Article 4.1.2 (b) combined with Article 4.5.3

Covered Taxes for uncertain tax position recorded as a reduction to Covered Taxes in prior year – Article 4.1.2 (c)

Qualified Refundable Tax Credit or Marketable Transferable Tax Credits recorded as a reduction to current tax expense – Article 4.1.2 (d)

Qualified Flow-through Tax Benefits of Qualified Ownership Interests – Article 3.2.1 (c)

Current tax expense on income excluded from GloBE Income or Loss – Article 4.1.3 (a)

Non-Qualified Refundable Tax Credit, Non-Marketable Transferable Tax Credit or Other Tax Credits not recorded as a reduction to current tax expense – Article 4.1.3 (b)

Covered Taxes refunded or credited (except for any Qualified Refundable Tax Credit, or Marketable Transferable Tax Credits) not treated as an adjustment to current tax expense – Article 4.1.3 (c)

Current tax expense related to uncertain tax position– Article 4.1.3 (d)

Current tax expense not expected to be paid within three years – Article 4.1.3 (e)

Post-filing adjustments – Article 4.6.1.

Covered Taxes relating to Net Asset Gain or Net Asset Loss – Article 3.2.6

Reduction of Covered Taxes of the UPE that is a Flow-through Entity – Article 7.1

Covered Taxes for GloBE Income of the UPE that is reduced under a Deductible Dividend Regime – Article 7.2.2

Deemed Distribution Tax – Article 7.3

Taxable Distribution Method election – Article 7.6 (b)

Total Deferred Tax Adjustment Amount – Article 4.4.1(b)

Increase or decrease in Covered Taxes recorded in equity or Other Comprehensive Income relating to amounts included in GloBE Income or Loss that will be subject to tax under local tax rules – Article 4.1.1 (c)

Excess Negative Tax Expense Carry Forward generated – Article 4.1.5 and 5.2.1

Decrease in Covered Taxes (but not below zero) by the remaining balance of the Excess Negative Tax Expense Carry-forward – Article 4.1.5 and 5.2.1

Enumeration options for Entity Owners

Governmental Entity

International Organisation

Non-profit Organisation

Pension Fund

Pension Fund that is not a Pension Services Entity

POPE IPE

De minimis election

Simplified Calculation for Non-material Constituent Entities

TIN Type

Tax Identification Number

Functionally equivalent number

Agreed GIR designated number

Not required to be reported

TIN Type

Local

CFS

Information in the message header identifies the Tax Administration that is sending the message. It specifies when the message was created, what period (normally a year) the report is for, and the nature of the report (original, corrected, supplemental, etc.).

GLOBE Version

Enumeration #6

Enumeration #7

Enumeration #8

%

Emumeration #8

%

Enumeration #9

%

%

Enumeration #10

Enumeration #16