18 February &  12 March 2025

18 February 2025 (13.00 - 15.00)
The components of the Jurisdictional ETR: GloBE Income or Loss

During this session Dr Bergedahl shall delve into:

• Departure point: Financial Accounting Net Income or Loss (FANIL)
• Article 3.1.2. Adjustments
• Treatment of Main Entities vs. PEs + PE loss importation / recapture rules
• Arm’s length adjustments
• Intra-Group Financing exception
• International Shipping Income Exclusion
• Elections (Realisation election, Aggregate Asset Gain or Loss election)

12 March 2025 (10.00 - 12.00)
The components of the Jurisdictional ETR: Adjusted Covered Taxes

In the second part of the session, Ms Demanuele Bianco will go through:

• Departure point: Current tax expense as per financial accounts
• Notion of Covered Taxes with specific reference to DRIT. − Total Deferred Tax Adjustment Amount
• Deferred Tax Recapture Rules
• Allocation of Covered Taxes to Constituent Entities (incl. Blended CFC Tax Rule)
• GloBE Loss Election