Deferred-tax tracking
The DTL chapter explains aggregation and tracking whether liabilities reverse within five years, with separate exceptions and unclaimed accruals. Another chapter addresses divergence between accounting and GloBE carrying values. These issues require records of when liabilities arose, how values differ and which exception is relied on; an accounting tax figure cannot simply be reused without the applicable GloBE adjustments.
Allocation and special structures
The package covers current and deferred cross-border taxes, flow-through structures and hybrid entities, and securitisation vehicles. It supplements the Commentary rather than replacing the model rules wholesale. Use the relevant chapter together with later guidance and domestic legislation to determine the required allocation in a particular group structure.
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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