From the group to each jurisdiction
The 2 October 2025 presentation starts with the EUR750 million group-revenue scope test and identifies ultimate parents, constituent entities, excluded entities and joint ventures. Constituent-entity classification relies on accounting consolidation and control, rather than one universal shareholding percentage. Entity locations and each jurisdiction’s IIR, UTPR and domestic top-up implementation dates then determine exposure and collection order. Examples contrast groups facing foreign rules in 2024 with Singapore’s financial years beginning from 1 January 2025.
The calculation bridge
After checking safe harbours and de minimis treatment, the workshop builds GloBE income and adjusted covered taxes, calculates jurisdictional ETR and reduces profits by the substance-based exclusion. The top-up amount is then allocated under the applicable rules, with domestic top-up tax taken into account. These are teaching examples as at the presentation date. Later 2026 modules and amendment notes should be consulted for subsequent changes; the workshop is not a current-rate certificate or a substitute for transaction-specific computation.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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