Pillar Two

Longview supports the calculation of ETR and top-up tax in support of the OECD’s BEPS Pillar Two model rules. Pillar Two apps, reports and administration can be found within the Global Transparency module in the Longview Client.

Overview of the Pillar Two process

The Pillar Two Model Rules are supported by several inputs, reports, and calculations. The basic flow of the process is:

• Source trial balance data is imported.
  • Your system may have additional source data imports.
• If you are using Tax Provision,
  • Automations that use source trial balance will execute.
  • Tax inputs will trigger additional tax calculations.
  • GloBE Temporary Differences will populate with provision balances for deferred tax accounts.
• GloBE Income will be populated using any configured automation.
• GloBE Covered Taxes will be populated using any configured automation.
• GloBE Temporary Differences adjustments will be populated using any configured automation.

• If your reporting currency is not EUR, adjust thresholds using Pillar Two Thresholds.

• Optionally use GloBE Revenue to enter the GloBE Revenue for each constituent entity.
  • This can be used as part of the de minimis test for a jurisdiction.
• Use GloBE Income to enter any manual inputs to GloBE Income for each constituent entity.
• Use GloBE Temporary Differences to enter any manual adjustments to temporary differences for Pillar Two.
• Use Adjusted Covered Taxes to enter any manual inputs to Covered Taxes and the Total Deferred Tax Adjustment for each constituent entity.
  • The Total Deferred Tax Adjustment is automatically transferred to the Total Deferred Tax Adjustment Amount within Covered Taxes.
• The ETR and Top-up Tax Percentage will be calculated automatically by an event.
  • The results of these calculations are stored by jurisdiction in the related jurisdiction calculation entity.
• Use Substance-Based Income Exclusion to enter gross values to support the calculation of the substance-based income exclusion.
  • The substance-based income exclusion will be calculated and applied to the top-up tax calculation.
• If QDMTT is applicable to the jurisdiction:
  • Adjust Income for any differences in QDMTT rules for the jurisdiction.
  • Adjust Covered Taxes for any differences in QDMTT rules for the jurisdiction.
  • The ETR and Top-up Tax Percentage will be calculated automatically by an event.
    • The results of these calculations are stored by jurisdiction in the related jurisdiction calculation entity.
  • Adjust Substance-Based Income Exclusion for any differences in QDMTT rules for the jurisdiction.
    • The substance-based income exclusion will be calculated and applied to the top-up tax calculation.
  • Use Top-up Tax to adjust the top-up tax payable under QDMTT.

    • The adjusted top-up tax is automatically applied as a deduction in GloBE top-up tax.

• Use Top-up Tax to make any allowed adjustments to the Top-up tax for the jurisdiction.
• Jurisdictional top-up tax is allocated to constituent entities with GloBE Income automatically.
• Use Allocated Top-up Tax to review the Top-up tax allocated to constituent entities.
• Use Income Inclusion Rule to review the Top-up tax attributed to owners.

• Use Excess Negative Tax Expense to review excess negative tax expense related to article 4.1.5 .

• Use Under-taxed payments rule to manage UTPR factors and results.

• Use Additional Top-up tax to manage additional top-up tax generated from adjustments to prior fiscal years .

• If you are using Longview to capture return specific data, you may also want to:
  • Use GloBE Allocation of Income and Taxes to enter details of allocation of income and taxes between permanent establishments and flow through entities.
  • Use GloBE SBIE Allocations to enter details of allocation of payroll and assets to permanent establishments and owners of flow through entities.
  • Enter Transition Year Details for deferred tax balances and disposals.

Transitional Safe Harbours

A starter kit is provided with Longview Pillar Two to deploy hierarchies, events, and apps to support transitional safe harbours.

The starter kit contains the following items:

• A deployment app.
• An adjustment app to enter adjustments to transitional safe harbour values at a jurisdictional level.
• A report app to review transitional safe harbours across jurisdictions.
• An event to transfer source values into the transitional safe harbour accounts.

Before deploying the starter kit, modifications may be required depending on the functionality included in your system.

For further information, see "Deploying the transitional safe harbour starter kit".

Minimum Rate

The minimum rate is set at 15%, but an input app has been provided to support potential future rate changes. You can set the minimum rate using:

• P2501 – Minimum Tax Rate input app found in Global Transparency > Data Collection > Pillar Two > Rates.

The minimum rate is set on install and copied forward during rollover.

QDMTT Minimum Rate

The minimum rate is set at 15%, but an input app has been provided to support potential future rate changes. You can set the minimum rate using:

• QD501 – Minimum Tax Rate input app found in Global Transparency > Data Collection > QDMTT > Jurisdictions

The minimum rate is copied forward during rollover.

Note: QDMTT Minimum Rate input will not be available for any jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

Pillar Two Thresholds

The GloBE Pillar Two model rules define specific thresholds for amounts denoted in EUR. In cases where these thresholds change in the future or you reporting currency is not EUR, you can adjust them using the Pillar Two Thresholds input app. There are several thresholds presented, but the ones used within the system are:

• Average GloBE Revenue (in transitional safe harbours).

• The Exchange rate for non-EUR reporting currency (in the GIR extract to csv).

To adjust Pillar Two Thresholds:

1. In Longview Client, select the Global Transparency module.

2. Select the Data Collection category in the navigation pane.

3. Expand Pillar Two.

4. Expand Rates and click P2503 – Pillar Two Thresholds. The app appears in the workspace.

5. Adjust the threshold in EUR as required.

6. If your reporting currency is not EUR, enter the exchange rate to use. The threshold in reporting currency is automatically calculated.

7. Click Submit to save your changes.

GloBE Revenue

The computation of GloBE Revenue is supported by:

• P2210 – GloBE Revenue input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2200 – GloBE Revenue report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

The accounts for GloBE Revenue are named and ordered using the articles outlined in section 3 of the OECD’s GloBE Model Rules for Pillar Two.

Input

Specific accounts within the input app will be protected based on elections taken for the jurisdiction the entity resides in, or the entity itself if it is stateless.

Election	Accounts Protected
3.2.8 Intra-group transactions election	3.2.8 - Election to consolidate transactions in same jurisdiction and its descendants, if election is not taken

Report

The GloBE Revenue report allows you to review the GloBE Revenue for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

GloBE Income

The computation of GloBE income or loss is supported by:

• P2200 – GloBE Income input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2200 – GloBE Income report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

The accounts for GloBE Income are named and ordered using the articles outlined in section 3 of the OECD’s GloBE Model Rules for Pillar Two.

Input

Specific accounts within the input app will be protected based on elections taken for the jurisdiction the entity resides in, or the entity itself if it is stateless.

Election	Accounts Protected
[3.2.1] Debt Release election	3.2.1 - Debt Releases and its descendants, if election is not taken
3.2.2 Stock Based Compensation	3.2.2 - Stock-based Compensation and its descendants, if election is not taken
3.2.5 Realisation Principle Election	3.2.5 - Election to use realisation method in lieu of fair value accounting and its descendants, if election is not taken
3.2.6 Aggregate Asset Gain Election	3.2.6 - Election to spread aggregate asset gains over five years, and its descendants, if election is not taken
3.2.8 Intra-group transactions election	3.2.8 - Election to consolidate transactions in same jurisdiction and its descendants, if election is not taken
[7.6] Taxable distribution method election	7.6.1 - Taxable Distribution Method Election, if election is not taken

Additionally, accounts configured for automation will be protected from input. See Managing GloBE income automations for more information.

Report

The GloBE Income report allows you to review the GloBE Income for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

QDMTT Income

The computation of QDMTT income or loss is supported by:

• QD200 – QDMTT Income input app found in Global Transparency > Data Collection > QDMTT > Constituent Entities.
• QD200 – QDMTT Income report found in Global Transparency > Reports > QDMTT > Constituent Entities.

Input

QDMTT Income is entered as an adjustment to the GloBE Income. The GloBE Income amounts are displayed and not editable, with an adjustment column available to apply any adjustments required. Any GloBE elections taken will also be applied.

Note: QDMTT Income input will not be available for any entity that is in a jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

Report

The QDMTT Income report allows you to review the QDMTT Income for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction

• The total of all jurisdictions

The report displays the GloBE Income amounts, QDMTT adjustments, and QDMTT adjusted values.

GloBE Temporary Differences

The computation of temporary differences is supported by:

• P2310 – GloBE Temporary Differences input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2310 – GloBE Transition Year input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2310 – GloBE Temporary Differences report found in Global Transparency > Reports > Pillar Two > Constituent Entities.
• P2311 – GloBE Transition Year report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

The accounts for Temporary Differences are named and ordered using the articles outlined in section 4 of the OECD’s GloBE Model Rules for Pillar Two. GloBE temporary differences provide a mechanism to:

• Show temporary differences per provision and at the global minimum rate to facilitate the calculation of any recast adjustment.
• Adjust deferred taxes below the temporary differences.
• Use the temporary difference adjustments as a source for automation of amounts within covered taxes.

Provision temporary differences are populated in Pillar Two with the element mapping outlined in the following tables.

Gross balance element mapping:

Target Element	Source Element ASC	Source Element IAS
P2BoY – Beginning of year	GrsBOY_ASC	GrsBOY_IAS
P2BS – Balance sheet movements	GrsAcqCur_ASC GrsAcqPR_ASC GrsDisp_ASC	GrsAcqCur_IAS GrsAcqPR_IAS GrsDisp_IAS
P2PY – Prior year adjustments	GrsPY_ASC	GrsPYAdj_IAS GrsRTPCurDfd_IAS
P2CY – Income statement	GrsCY_ASC GrsPYAdjDfd_ASC GrsRTPDfd_ASC GrsRARDfd_ASC GrsCurDfd_ASC GrsDfd_ASC GrsTrfrCurDfd_ASC GrsTrfrDfd_ASC GrsUDiff_ASC	GrsCY_IAS GrsCYOthCurDfd_IAS GrsCYOthDfd_IAS GrsCYTrfr_IAS GrsUDiff_IAS
P2OCI – OCI	GrsNPOCI_ASC GrsNPOCIOth_ASC GrsRTPNPOCIDfd_ASC	GrsOCI_IAS GrsOCIOth_IAS GrsRTPOCICurDfd_IAS GrsCTABOY_IAS GrsCTACY_IAS
P2Eq – Equity	GrsNP123_ASC GrsNPOth_ASC GrsNPEqOth_ASC GrsRTPNPEqDfd_ASC GrsUDiffEq_ASC	GrsEq_IAS GrsEQOth_IAS GrsRTPEqCurDfd_IAS GrsUDiffEq_IAS
P2CTA - CTA (ASC only)	GrsCTABOY_ASC GrsCTACY_ASC

Net balance element mapping:

Target Element	Source Element ASC	Source Element IAS
P2BoY – Beginning of year	NetNBOY_ASC NetNBRBOY_ASC NetRBOY_ASC	NetNBOY_IAS   NetNBRBOY_IAS NetRBOY_IAS   MSP_NetRBOYConsAdj_IAS
P2PYDTNR – Prior Year DTNR		NetNDTNRPY_IAS NetRDTNRPY_IAS
P2BS – Balance sheet movements	NetNRCAcqP_ASC NetNRCAcqC_ASC NetNDisp_ASC NetRAcqPR_ASC NetRAcqCur_ASC NetRDisp_ASC	NetNAcqPR_IAS NetNAcqCur_IAS NetNDisp_IAS NetRAcqPR_IAS NetRAcqCur_IAS NetRDisp_IAS
P2PY – Prior year adjustments	NetNPY_ASC NetNBRPY_ASC NetRAcqPR_ASC NetRAcqCUR_ASC NetRDisp_ASC NetRPY_ASC	NetNPYAdj_IAS NetNRTPCurDfd_IAS NetNBRPY_IAS NetRAcqPR_IAS NetRAcqCur_IAS NetRDisp_IAS NetRPYAdj_IAS NetRRTPCurDfd_IAS MSP_NetRPYConsAdj_IAS MSP_NetRPYGrpBOYAdj_IAS
P2CY – Income statement	NetNCY_ASC NetNPYAdjDfd_ASC NetNRTPDfd_ASC NetNRARDfd_ASC NetNCurDfd_ASC NetNDfd_ASC NetNTrfrCurDfd_ASC NetNTrfrDfd_ASC NetNUDiff_ASC NetNBRDP_ASC NetRCY_ASC NetRPYAdjDfd_ASC NetRRTPDfd_ASC NetRRARDfd_ASC NetRCurDfd_ASC NetRDfd_ASC NetRTrfrCurDfd_ASC NetRTrfrDfd_ASC NetRUDiff_ASC MSP_NetRCYGrpBOYAdj_ASC	NetNCY_IAS NetNCYOthCurDfd_IAS NetNCYOthDfd_IAS NetNCYTrfr_IAS NetNUDiff_IAS NetNBRCYT_IAS NetRCY_IAS NetRCYOthCurDfd_IAS NetRCYOthDfd_IAS NetRCYTrfr_IAS NetRUDiff_IAS MSP_NetRCYTConsAdj_IAS MSP_NetRCYTGrpBOYAdj_IAS
P2CYRC - Current Year Rate Change	NetNRCBOY_ASC NetNBRRCBOY_ASC NetNRCCY_ASC NetNBRRCCY_ASC NetNRCAcqPR_ASC NetNRCAcqCR_ASC NetRRCBOY_ASC NetRRCCY_ASC NetRRCAcqP_ASC NetRRCAcqC_ASC NetRRCAcqPR_ASC NetRRCAcqCR_ASC MSP_NetRAFCBOY_ASC MSP_NetRAFCCY_ASC	NetNRCBOY_IAS NetNBRRCBOY_IAS NetNRCCY_IAS NetNBRRCCY_IAS NetNRCAcqP_IAS NetNRCAcqC_IAS NetNRCAcqPR_IAS NetNRCAcqCR_IAS NetRRCBOY_IAS NetRRCCY_IAS NetRRCAcqP_IAS NetRRCAcqC_IAS MSP_NetRAFCBOY_IAS MSP_NetRAFCCY_IAS NetRRCAcqPR_IAS NetRRCAcqCR_IAS
P2CYDTNR - Change in DTNR (IAS only)		NetNDTNRChg_IAS NetRDTNRChg_IAS
P2OCI – OCI	NetNNPOCI_ASC NetNRTPNPOCIDfd_ASC NetNNPOCIOth_ASC NetNBRNPOCI_ASC NetNNPOCIRCBOY_ASC NetNBRNPOCIRCBOY_ASC NetNNPOCIRCCY_ASC NetNBRNPOCIRCCY_ASC NetRNPOCI_ASC NetRRTPNPOCIDfd_ASC NetRNPOCIOth_ASC NetRNPOCIRCBOY_ASC NetRNPOCIRCCY_ASC MSP_NetRNPOCIGrpBOYAdj_ASC MSP_NetRNPOCIAFCBOY_ASC MSP_NetRNPOCIAFCCY_ASC	NetNOCI_IAS NetNRTPOCICurDfd_IAS NetNDTNRCOCI_IAS NetNOCIOth_IAS NetNOCIRCBOY_IAS NetNBROCIRCBOY_IAS NetNOCIRCCY_IAS NetNBROCIRCCY_IAS NetNBROCI_IAS NetNCTABOY_IAS NetNCTACY_IAS NetROCI_IAS NetRRTPOCICurDfd_IAS NetRDTNRCOCI_IAS NetROCIOth_IAS NetROCIRCBOY_IAS NetROCIRCCY_IAS MSP_NetROCIAFCBOY_IAS MSP_NetROCIAFCCY_IAS MSP_NetRCTABOY_IAS MSP_NetRCTACY_IAS MSP_NetROCIConsAdj_IAS MSP_NetROCIGrpBOYAdj_IAS NetRCTABOY_IAS (non-MRP only) NetRCTACY_IAS (non-MRP only)
P2Eq – Equity	Invisible: New for v24.4NetNNP123_ASC NetNNPOth_ASC NetNRTPNPEqDfd_ASC NetNNPEqOth_ASC NetNUDiffEq_ASC NetNBRNPEq_ASC NetNNPEqRCBOY_ASC NetNBRNPEqRCBOY_ASC NetNNPEqRCCY_ASC NetNBRNPEqRCCY_ASC NetRNP123_ASC NetRNPOth_ASC NetRRTPNPEqDfd_ASC NetRNPEqOth_ASC NetRUDiffEq_ASC NetRNPEqRCBOY_ASC NetRNPEqRCCY_ASC MSP_NetRNPEqGrpBOYAdj_ASC MSP_NetRNPEqAFCBOY_ASC MSP_NetRNPEqAFCCY_ASC	Invisible: New for v24.4NetNEQ_IAS NetNRTPEQCurDfd_IAS NetNDTNRCEq_IAS NetNEQOth_IAS NetNUDiffEq_IAS NetNEqRCBOY_IAS NetNBREqRCBOY_IAS NetNEqRCCY_IAS NetNBREqRCCY_IAS NetNBREq_IAS NetREQ_IAS NetRRTPEQCurDfd_IAS NetRDTNRCEq_IAS NetREQOth_IAS NetRUDiffEq_IAS NetREqRCBOY_IAS NetREqRCCY_IAS MSP_NetREqAFCBOY_IAS MSP_NetREqAFCCY_IAS MSP_NetREqConsAdj_IAS MSP_NetREqGrpBOYAdj_IAS
P2CTA - CTA (ASC only)	NetNCTABOY_ASC NetNCTACYR_ASC NetRCTABOY_ASC NetRCTACYR_ASC

Input

Specific symbols within the input app will be protected:

Symbol	Note
P2TMP4.1.1 – Temporary Differences per Provision (ACCOUNTS)	Temporary Differences per Provision and its descendants, as these values come from tax provision calculations.
P2NetP2 – Net per Pillar Two (DETAILS)	Net per Pillar Two Minimum Rate is calculated as follows: For temporary differences entered as gross in tax provision, if the ETR for the account/element is > global minimum rate: Gross multiplied by the global minimum rate. For temporary differences entered as gross in tax provision, if the ETR for the account/element is <= global minimum rate: Net per provision For temporary differences entered as net in tax provision: Net per provision. For the DTNR and rate change elements the value is always zero . Manual input for all other adjustments.
P2NetTP - Net per Provision (DETAILS)	Net per Provision is calculated from the provision temporary differences. For all other adjustments, you may enter values for this detail.
P2Recast – Recast Adjustment	The recast adjustment is calculated for gross temporary differences as the difference between the net per pillar two and net per provision.The recast calculation does not apply to the DTNR or rate change elements.The recast adjustment is open for input for any temporary differences that are not entered as gross and all other pillar two adjustments.

Additionally, accounts configured for automation will be protected from input. For more information, see Managing GloBE temporary difference automations.

Report

The GloBE Temporary Differences report allows you to review the GloBE Temporary Differences for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

GloBE Adjusted Covered Taxes

The computation of adjusted covered taxes is supported by:

• P2300 – GloBE Adjusted Covered Taxes input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2300 – GloBE Adjusted Covered Taxes report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

The accounts for Adjusted Covered Taxes are named and ordered using the articles outlined in section 4 of the OECD’s GloBE Model Rules for Pillar Two.

Input

Specific accounts withing the input app will be protected based on elections taken for the jurisdiction the entity resides in, or the entity itself if it is stateless.

Election	Accounts Protected
4.5 GloBE Loss Election	3 4.1.2.b - GloBE Loss Deferred Tax Asset used (4.5 election) and its descendants, if election is not taken
4.5 GloBE Loss Election	4.4 - Covered Taxes - Deferred and its descendants, if election is taken
7.3.1 Deemed Distribution Tax Election	7.3.1 - Deemed Distribution Tax, and its descendants, if election is not taken

Additionally, accounts configured for automation will be protected from input. See Managing GloBE adjusted covered tax automations for more information.

Report

The GloBE Adjusted Covered Taxes report allows you to review the GloBE Adjusted Covered Taxes for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

QDMTT Adjusted Covered Taxes

The computation of QDMTT covered taxes is supported by:

• QD300 – QDMTT Adjusted Covered Taxes input app found in Global Transparency > Data Collection > QDMTT > Constituent Entities.
• QD300 – QDMTT Adjusted Covered Taxes report found in Global Transparency > Reports > QDMTT > Constituent Entities.

Input

QDMTT Adjusted Covered Taxes is entered as an adjustment to the GloBE Adjusted Covered Taxes. The GloBE Adjusted Covered Taxes amounts are displayed and not editable, with an adjustment column available to apply any adjustments required. Any GloBE elections taken will also be applied.

Note: QDMTT Adjusted Covered Taxes input will not be available for any entity that is in a jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

Report

The QDMTT Covered Taxes report allows you to review the QDMTT Covered Taxes for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

The report displays the GloBE Adjusted Covered Taxes amounts, QDMTT adjustments, and QDMTT adjusted values.

GloBE ETR and Top-up Tax Percentage

ETR and Top-up tax percentage is calculated by event calculations for each included Jurisdiction and Stateless Constituent entity using the values entered for GloBE Income and Adjusted Covered Taxes.

The top-up tax percentage is the greater of:

• Zero, and
• "Minimum tax rate" less “ETR”

ETR and Top-up Tax Percentage can be reviewed using:

• P2500 – Top-up Tax Percentage report found in Global Transparency > Reports > Pillar Two > Jurisdictions.

The Top-up Tax Percentage report allows you to review the Top-up tax percentage for:

• A stateless constituent entity
• A jurisdiction

QDMTT ETR and Top-up Tax Percentage

ETR and Top-up tax percentage is calculated by event calculations for each included Jurisdiction and Stateless Constituent entity using the values entered for QDMTT Income and Adjusted Covered Taxes.

The top-up tax percentage is the greater of:

• Zero, and
• "Minimum tax rate" less "ETR"

ETR and Top-up Tax Percentage can be reviewed using:

• QD500 – Top-up Tax Percentage report found in Global Transparency > Reports > QDMTT > Jurisdictions.

The Top-up Tax Percentage report allows you to review the Top-up tax percentage for:

• A stateless constituent entity
• A jurisdiction

Substance-Based Income Exclusion

The computation of substance-based income exclusion is supported by:

• P2502 – Substance-based income exclusion rates input app found in Global Transparency > Data Collection > Pillar Two > Rates.
• P2205 – Substance-based income exclusion input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.
• P2205 – Substance-based income exclusion report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

P2502 Input

Input the substance-based income exclusion rate applicable for payroll and tangible assets. Rates are defined in section 9.2 of the OECD’s Pillar 2 Model Rules and change by year until 2033, when they reach the prescribed 5% mark.

P2205 Input

The input app is not available for entities in jurisdictions or stateless entities that have taken the 5.3.1 election to not apply the substance-based exclusion.

Accounts in the input app are included to:

• Capture gross payroll and tangible asset amounts for a constituent entity.
• Capture any adjustments required for permanent establishments and flow-through entities under articles 5.3.6 and 5.3.7.
• Display the current rates for payroll carve-out and tangible asset carve-out amounts.
• Display the amount of substance-based income exclusion generated by the entity.

Report

The Substance-based Income Exclusion report allows you to review the amounts for:

• A constituent entity
• A jurisdiction
• The total of all jurisdictions

QDMTT Substance-Based Income Exclusion

The computation of QDMTT substance-based income exclusion is supported by:

• QD502 – Substance-based income exclusion rates input app found in Global Transparency > Data Collection > QDMTT > Jurisdictions.
• QD205 – QDMTT Substance-Based Income Exclusion input app found in Global Transparency > Data Collection > QDMTT > Constituent Entities.
• QD205 – QDMTT Substance-Based Income Exclusion report found in Global Transparency > Reports > QDMTT > Constituent Entities.

QD502 Input

Input the substance-based income exclusion rate applicable for payroll and tangible assets for QDMTT in the jurisdiction.

Note: QD502 input will not be available for any jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

QD205 Input

QDMTT Substance-Based Income Exclusion is entered as an adjustment to the GloBE Substance-Based Income Exclusion. The GloBE Adjusted Covered Taxes amounts are displayed and not editable, with an adjustment column available to apply any adjustments required. Any GloBE elections taken will also be applied.

Note: QD205 input will not be available for any entity that is in a jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

Report

The QDMTT Substance-Based Income Exclusion report allows you to review the QDMTT Substance-Based Income Exclusion for:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

The report displays the GloBE Substance-Based Income Exclusion amounts, QDMTT adjustments, and QDMTT adjusted values.

Adjusted Jurisdictional Top-up Tax

The computation of adjusted Jurisdictional Top-up Tax is supported by:

• P2510 – Top-up Tax input app found in Global Transparency > Data Collection > Pillar Two > Jurisdictions.
• P2510 – Top-up Tax report found in Global Transparency > Reports > Pillar Two > Jurisdictions.

Input

Specific accounts withing the input app will be protected based on elections taken for the jurisdiction the entity resides in, or the entity itself if it is stateless.

Election	Accounts Protected
5.3.1 Do Not Apply Substance-Based Income Exclusion	Aggregate Substance-based income exclusion

Report

The Adjusted Jurisdictional Top-up Tax report allows you to review the Top-up taxes for:

• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

QDMTT Adjusted Top-up Tax

The computation of QDMTT adjusted Top-up Tax is supported by:

• QD510 – Top-up Tax input app found in Global Transparency > Data Collection > QDMTT > Jurisdictions.
• QD510 – Top-up Tax report found in Global Transparency > Reports > QD510 > Jurisdictions.

Input

Specific accounts withing the input app will be protected based on elections taken for the jurisdiction the entity resides in, or the entity itself if it is stateless.

Election	Accounts Protected
5.3.1 Do Not Apply Substance-Based Income Exclusion	Aggregate Substance-based income exclusion

Note: QDMTT Top-up Tax input will not be available for any jurisdiction that does not have QDMTT selected in Applicable Rules within Manage Jurisdiction Elections.

Report

The Adjusted Jurisdictional Top-up Tax report allows you to review the Top-up taxes for:

• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

Allocated Top-up Tax

Once top-up tax is calculated for a jurisdiction it is allocated to the constituent entities members of the jurisdiction that have GloBE Income. The allocated top-up tax report allows you to review the top-up tax allocated for:

• The constituent entities of a jurisdiction
• All constituent entities across all jurisdictions

The report is presented with the allocated top-up tax accounts across and the entities down. By default, the entities will be collapsed to the selected jurisdiction. Click on the jurisdiction to expand it to view the constituent entities. Currently, values are calculated only for top-up tax allocated under section 5.2.4 of the model rules.

To review the allocated top-up taxes:

1. In Longview Client, select the Global Transparency module.
2. Select the Reports category in the navigation pane.
3. Expand the Pillar Two folder.
4. Expand the Jurisdictions folder.
5. Use the drop-down list or the symbol selector to select the appropriate jurisdiction. For more information, see Using the Symbol Selector.
6. Click P2520 – Allocated Top-up Tax.rtp. The report opens in the workspace.
7. Review the top-up taxes allocated to the selected entities.

Income Inclusion Rule

After the top-up tax is allocated to constituent entities it is assigned to the owners of those entities using the income inclusion rule. The top-up tax is allocated using the rules outlined in Articles 2.1, 2.2 and 2.3 of the Pillar Two Model Rules.

The attributed top-up tax displays the amount of top-up tax attributed to parent entities from each constituent entity and any offset amount.

Report

The Attributed Top-up Tax report allows you to review the Top-up taxes attributed to parent entities:

• A constituent entity
• A stateless constituent entity
• A jurisdiction
• The total of all jurisdictions

To review the attributed top-up taxes:

1. In Longview Client, select the Global Transparency module.
2. Select the Reports category in the navigation pane.
3. Expand the Pillar Two folder.
4. Expand the Constituent Entities folder.
5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see Using the Symbol Selector.
6. Click P2530 – Attributed Top-up Tax.rtp. The report opens in the workspace.
7. Review the top-up taxes attributed to the selected entities, from each constituent entity.

Excess Negative Tax Expense

Excess negative tax expense is generated when the effective negative tax expense on a loss exceeds the global minimum rate. Under Article 4.1.5 this amount either generates additional top-up tax in the current year or is carried forward to a future year to be taken as a reduction to covered taxes.

The components of excess negative tax expense include:

• Expected Adjusted Covered Taxes Amount

• The Article 4.1.5 jurisdictional election to apply the excess negative tax expense carry-forward.

• The calculation of:

  • Excess negative tax expense when the Article 4.1.5 election is not taken.

  • Excess negative tax expense carry-forward, generated or used when the Article 4.1.5 election is taken.

• P2320 – GloBE Excess Negative Tax Expense report, which displays:

  • Expected Adjusted Covered Taxes Amount

  • Excess Negative Tax Expense Carry-forward Remaining Balance, which includes:

    • The prior year balance.

    • Excess negative tax expense generated.

    • Decrease in covered taxes by excess negative tax expense.

  • Top-up Tax related to a Jurisdiction with no GloBE Income

• QD320 – QDMTT Excess Negative Tax Expense report, which displays:

  • Expected Adjusted Covered Taxes Amount

  • Excess Negative Tax Expense Carry-forward Remaining Balance, which includes:

    • The prior year balance.

    • Excess negative tax expense generated

    • Decrease in covered taxes by excess negative tax expense

  • Top-up Tax related to a Jurisdiction with no GloBE Income

To access the GloBE excess negative tax expense report :

1. In Longview Client, select the Global Transparency module.

2. Select the Reports category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Jurisdiction folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2320 – GloBE Excess Negative Tax Expense. The report opens in the workspace.

To access the QDMTT excess negative tax expense report :

1. In Longview Client, select the Global Transparency module.

2. Select the Reports category in the navigation pane.

3. Expand the QDMTT folder.

4. Expand the Jurisdiction folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click QD320 – QDMTT Excess Negative Tax Expense. The report opens in the workspace.

Under-taxed payments rule

After top-up tax has been attributed to owners, any remaining top-up tax may be subject to the under-taxed payments rule (UTPR). This rule determines the amount of top-up tax that was not attributed to an owner and distributes it to jurisdictions that have implemented the under-taxed payments rule using an allocation factor based on assets and number of employees.

The total UTPR top-up tax amount is calculated as the difference between the allocated top-up tax amount for a constituent entity and the total top-up tax attributed to the owners of that constituent entity. The total amount across all constituent entities is then allocated using the Under-Taxed Payments Rule.

The under-taxed payments rule is supported by:

• P2600 – Under Taxed Payment Rule input app found in Global Transparency > Data Collection > Pillar Two > Jurisdictions.

• P2610 – UTPR Allocation Factors input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.

• P2600 – Under Taxed Payment Rule report found in Global Transparency > Reports > Pillar Two > Jurisdictions.

P2600 Input

Use P2600 Under Taxed Payment Rule to review the inputs and calculation results for the Under-Taxed Payments Rule and provide any additional cash tax expense incurred under the rule.

To access the Under-Taxed Payments Rule:

1. In Longview Client, select the Global Transparency module.

2. Select the Data Collection category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Jurisdiction folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2600 – Under Taxed Payment Rule. The app opens in the workspace.

P2610 Input

Use P2610 UTPR Allocation Factors to capture the number of employees and net book value of tangible assets by constituent entity. These factors are used in determining the allocation percentage used in the under-taxed payments rule.

To access the UTPR allocations factors input:

1. In Longview Client, select the Global Transparency module.

2. Select the Data Collection category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Constituent Entities folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2610 – UTPR Allocation Factors. The app opens in the workspace.

P2600 Report

Use P2600 Under Taxed Payment Rule report to review the UTPR results for one or more jurisdictions.

To access the Under-Taxed Payments Rule report:

1. In Longview Client, select the Global Transparency module.

2. Select the Reports category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Jurisdictions folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2600 – Under Taxed Payment Rule. The report opens in the workspace.

Additional Top-up tax

Additional top-up tax arises when there is an adjustment to a previously reported year that causes a change in the top-up tax amount. Any top-up tax determined in a previous year is applied as additional top-up tax in the current year.

Additional top-up tax is supported by:

• P2515 – Additional top-up Tax Adjustments input app found in Global Transparency > Data Collection > Pillar Two > Constituent Entities.

• P2515 – Additional Top-up Tax report found in Global Transparency > Reports > Pillar Two > Constituent Entities.

P2515 Input

Use P2515 Additional Top-up Tax Adjustments to adjust GloBE Income and Covered Taxes for up to the five previous fiscal years. Specific accounts are provided for adjustments to GloBE Income and Covered Taxes that align with the articles that require adjustments to previous years results.

To access Additional Top-up Tax Adjustments:

1. In the Longview Client, select the Global Transparency module.

2. Select the Data Collection category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Constituent Entities folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2515 – Additional Top-up Tax Adjustments. The app opens in the workspace.

P2515 Report

Use P2515 Additional Top-up Tax to review additional top-up tax generated for a jurisdiction in the previous five fiscal years.

To access Additional Top-up Tax:

1. In the Longview Client, select the Global Transparency module.

2. Select the Reports category in the navigation pane.

3. Expand the Pillar Two folder.

4. Expand the Jurisdictions folder.

5. Use the drop-down list or the symbol selector to select the appropriate entity. For more information, see “Using the Symbol Selector”.

6. Click P2512 – Additional Top-up tax. The report opens in the workspace.

Entering allocation details for income and taxes

The GloBE Allocation of Income and Taxes app is used to provide the details of allocations between permanent establishments and flow-through entities required for the GloBE Information Return. The data collected by the GloBE Allocation of Income and Taxes app is supplemental data for GloBE Information Return purposes only and is not applied to the related accounts within the GloBE Income and Covered Taxes hierarchies.

 

To access income and tax allocation input:

1. In the Longview Client, select the Global Transparency module.
2. Click on the Data Collection category.
3. Expand Pillar Two and expand Constituent Entities.
4. Optionally select an entity from the provided symbol selector.
5. Click on P2201 – GloBE Allocation of Income and Taxes.
6. Select the period, if prompted and click OK. The allocation of income and taxes input table appears.
7. Update the allocation data as necessary and click Submit to save the changes.
   1. Prior to the allocation details being saved the data will be validated. Any validation errors will prevent the data from being saved.
8. When finished close the P2201 – GloBE Allocation of Income and Taxes tab.

For general information on working with this table, see “Working with Longview data tables”.

To add a new allocation detail:

1. Click Add. Alternatively, if the new allocation detail is similar to an existing one, click on the row and click Duplicate.

2. Select the Basis for the allocation. The basis is tied to a specific article within the GloBE rules.

3. Select the source entity. The entity must be a leaf and cannot be the jurisdiction calculation entity.

4. Enter the amount of income or tax being allocated.

To create an import file for allocation detail:

1. Create a new command separated values file (.csv).

2. Add a header row with the values Basis, Source Entity, Amount.

3. For each allocation detail:

   1. Specify the allocation basis as one of the following values:

   1. Income - Article 3.4
   2. Income - Article 3.5.3
   3. Income - Article 3.5.1(a)
   4. Income - Article 3.5.1(b)
   5. Income - Article 3.2.3
   6. Income - Article 3.2.7
   7. Taxes - Article 4.3.2(a)
   8. Taxes - Article 4.3.2(b)
   9. Taxes - Article 4.3.2(c)
   10. Taxes - Article 4.3.2(d)
   11. Taxes - Article 4.3.2(e)
   12. Taxes - Article 4.3.3(a)
   13. Taxes - Article 4.3.3(b)
   14. Taxes - Article 4.3.4
   15. Taxes - Article 4.3.2(c) - Blended CFC Regime

   2. Specify the name of the source entity symbol. You must enclose the symbol name in square brackets if it is numeric.

   3. Specify the allocation amount.

4. Save the file.

The following issues will prevent the allocation details from being saved:

• Multiple rows have the same Basis and Source Entity combination.

• The source entity and the entity are the same.

The sum of all percentages for an entity does not equal 100.

Entering allocation details for substance-based income exclusion

The GloBE SBIE Allocations app is used to provide the details of allocations between permanent establishments and flow-through entities required for the GloBE Information Return. The data collected by the GloBE SBIE Allocations app is supplemental data for GloBE Information Return purposes only and is not applied to the related accounts within the Substance-based Income Exlcusion hierarchy.

To access substance-based income exclusion input:

1. In the Longview Client, select the Global Transparency module.
2. Click on the Data Collection category.
3. Expand Pillar Two and expand Jurisdictions.
4. Optionally select an entity from the provided symbol selector.
5. Click on P2206 – GloBE SBIE Allocations.
6. Select the period, if prompted and click OK. The SBIE allocations input table appears.
7. Update the allocation data as necessary and click Submit to save the changes.
   1. Prior to the allocation details being saved the data will be validated. Any validation errors will prevent the data from being saved.
8. When finished close the P2206 – GloBE SBIE Allocations tab.

For general information on working with this table, see “Working with Longview data tables”.

To add a new allocation detail:

1. Click Add. Alternatively, if the new allocation detail is similar to an existing one, click on the row and click Duplicate.

2. Select the Allocation Type for the allocation. The allocation type indicates whether the allocation is related to a permanent establishment or flow-through entity.

3. Select the country.

   1. For permanent establishments, this is the country that the permanent establishment is located in.

   2. For flow-through entity, this is the country that the constituent entity owner is located in.

4. Indicate if the owner of the permanent establishment or flow-through entity is the UPE.

5. Enter the total eligible payroll costs.

   1. For permanent establishment, this is the Relevant Eligible Payroll Costs for all Main Entities located in the jurisdiction before any adjustments under Article 5.3.6 (Permanent Establishments)

   2. For flow-through entity, this is the aggregate relevant Eligible Payroll Costs for all Flow-through Entities located in the jurisdiction after any adjustments under Article 5.3.6 (Permanent Establishments) and before any adjustments under Article 5.3.7 (Flow-Through Entities).

6. Enter the amount of payroll costs allocated to the permanent establishment or constituent entity owner.

7. Enter the total tangible assets.

   1. For permanent establishment, this is the aggregate carrying value of the Relevant Eligible Tangible Assets for all Main Entities located in the jurisdiction before any adjustments under Article 5.3.6 (Permanent Establishments)

   2. For flow-through entity, this is the aggregate relevant Eligible Payroll Costs for all Flow-through Entities located in the jurisdiction after any adjustments under Article 5.3.6 (Permanent Establishments) and before any adjustments under Article 5.3.7 (Flow-Through Entities).

8. Enter the amount of total assets allocated to the permanent establishment or constituent entity owner.

To create an import file for allocation detail:

1. Create a new command separated values file (.csv).
2. Add a header row with the values Allocation Type, Country, Owner is UPE, Total Payroll, Allocated Payroll, Total Tangible Assets, Allocated Tangible Assets.
3. For each allocation detail:
   1. Specify the allocation type as one of the following values:
      1. PEAllocation
      2. FTEAllocation
   2. Specify the country of the permanent establishment or constituent entity owner as the 2-character ISO 3166-1 Alpha 2 standard for the jurisdiction.
   3. Specify 1, if the owner is the UPE or 0 otherwise.
   4. Specify the amount for total payroll, or NULL if payroll costs are not being allocated.
   5. Specify the amount for allocated payroll, or NULL if payroll costs are not being allocated.
   6. Specify the amount for total tangible assets, or NULL if tangible assets are not being allocated.
   7. Specify the amount for allocated tangible assets, or NULL if tangible assets are not being allocated.
4. Save the file.

The following issues will prevent the allocation details from being saved:

• If a value for Total Payroll is specified, but no value is specified for Allocated Payroll.

• If a value for Allocated Payroll is specified, but no value is specified for Total Payroll.

• If a value for Total Tangible Assets is specified, but no value is specified for Allocated Tangible Assets.

• If a value for Allocated Tangible Assets is specified, but no value is specified for Total Tangible Assets.

Entering transition year information

Transition Year Information app is used to provide the details required for the GloBE Information Return. The data collected for the transition year is not used in any calculations. Transition year disposals are required to be reported for assets disposed to Constituent Entities or members of JV Groups located in this jurisdiction after 30 November 2021 and before the commencement of a Transition Year.

Transition Year information collected includes:

• Transition year balances for deferred tax assets and liabilities.

  • Required to report the balances of deferred tax assets and liabilities at the start of the year of transition.

• Transition year disposals.

  • Required to report assets disposed to Constituent Entities or members of JV Groups located in this jurisdiction after 30 November 2021 and before the commencement of a Transition Year.

To provide transition year balances for deferred tax assets and liabilities

1. Open the Longview Client and navigate to Global Transparency > Data Collection and expand Pillar Two, then expand Constituent Entities.
2. Select an entity in the symbol selector in the navigation pane. Alternatively, you will be prompted to select an entity when opening GloBE Transition Year.
3. Click on P2311 – GloBE Transition Year. The GloBE Transition Year input view appears.

4. Enter transition year balances as required:

   Note: Only the Net per Pillar Two Minimum Rate value is required for the GloBE Information Return.

   1. Enter the gross, Net per Pillar Two Minimum Rate and Net per Provision for each temporary difference.

   2. The Recast value is calculated as Net per Provision less Net per Pillar Two Minimum Rate.

5. Click Submit to save your changes.

To provide transition year disposals for deferred tax assets and liabilities

1. Open the Longview Client and navigate to Global Transparency > Data Collection and expand Pillar Two, then expand Jurisdictions.

2. Select a jurisdiction in the symbol selector navigation pane. Alternatively you will be prompted to select a jurisdiction when opening GloBE Transition Year Disposals.

3. Click on P2312 – GloBE Transition Year Disposals. The GloBE Transition Year Disposals table input appears.

4. Click Add to add a new transition year disposal.

5. For each transition year disposal:

   1. Select the country the assets are disposed from.
   2. Enter the net amount of the aggregate pre-existing deferred tax assets
   3. or liabilities on the transferred asset(s) reflected in the financial accounts of the disposing Constituent Entity (or Constituent Entities).
      1. Deferred tax assets are reported as a positive number.
      2. Deferred tax liabilities are reported as a negative number.
   4. Enter the Carrying Value of the transferred assets for GloBE purposes as the beginning of the transition year.
      1. Deferred tax assets are reported as a positive number.
      2. Deferred tax liabilities are reported as a negative number.

   5. Enter the amount of tax paid in respect of the transaction(s).

   6. Enter the net deferred tax asset or liability with respect to the transferred assets for GloBE purposes. This is the net amount of the aggregate deferred tax assets and liabilities that should be recognised for purposes of the GloBE Rules at the beginning of the Transition Year with respect to the transferred assets.

      1. Deferred tax assets are reported as a positive number.

      2. Deferred tax liabilities are reported as a negative number.