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Commission Implementing Regulation (EU) 2025/1325 of 7 July 2025 amending Implementing Regulation (EU) 2015/2378 as regards the standard forms and computerised formats to be used for the mandatory automatic exchange of information under Council Directive 2011/16/EU as amended by Council Directive (EU) 2025/872

Type Implementing Regulation

Publication 2025-07-17

State In force

Text As published

Department European Commission, TAXUD

Source EUR-Lex

articles 2

This is the act as published. Later amendments are not folded into the text below: each one is a separate act in this repository and an entry in this law's history.

Reform history JSON API


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 % Enumeration #2 Enumeration #3 Enumeration #2 Enumeration #3 Enumeration #4 Enumeration #11 Enumeration #17 Enumeration #18 Enumeration #19 Enumeration #20 Enumeration #21 Enumeration #22 Enumeration #23 Enumeration #24 Enumeration #25 Enumeration #1 Enumeration #2 Enumeration #3 Enumeration #17 Free text % % Enumeration #11 % Enumeration #11 Enumeration #12 Enumeration #13 Enumeration #14 Enumeration #15

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 % Enumeration #2 Enumeration #3 Enumeration #2 Enumeration #3 Enumeration #4 Enumeration #11 Enumeration #17 Enumeration #18 Enumeration #19 Enumeration #20 Enumeration #21 Enumeration #22 Enumeration #23 Enumeration #24 Enumeration #25 Enumeration #1 Enumeration #2 Enumeration #3 Enumeration #17 Free text % % Enumeration #11 % Enumeration #11 Enumeration #12 Enumeration #13 Enumeration #14 Enumeration #15

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