Income and expense adjustments
The slides cover tax expense, acquisition accounting, excluded dividends and equity gains, revaluation, asymmetric foreign exchange, illegal payments, fines, pensions and arm’s-length requirements. Short-term portfolio dividends are not automatically excluded: the illustrated portfolio test concerns rights below 10% and holding below one year. A material fine or penalty threshold of EUR50,000 includes aggregation for the same or continuing conduct. Associated covered taxes generally follow the exclusion of the underlying income. These are prescribed GloBE adjustments, not a general permission to remove every locally exempt receipt.
Branches and shipping
International shipping income has a defined exclusion, with limits for ancillary income and related costs. A main entity generally removes permanent-establishment accounting income, but specified branch losses can be allocated to the main entity and matched by later positive income. Amounts attributed from flow-through entities are adjusted as part of the receiving owner’s income. Track these transfers and subsequent reversals by entity and year to avoid counting the same branch or flow-through amount twice.
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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