Summary
Use the OECD guidance together with our clarifications below to avoid errors or comments in Summary when submitting the GloBE Information Return to us. Guidance on completing the XML file is set out in the XML Schema User Guide, pages 35–41.
Summary contains information summarised by country, including Safe Harbour rules and exclusions, as well as information on which countries have taxing rights.
Summary must be completed in accordance with the XML Schema User Guide, pages 35–41. This also applies where the XML file is not intended for exchange (centralised filing). This means that the Summary must contain information for all countries and, where relevant, entities or subgroups within a country for which separate calculations must be performed, regardless of where they're located. Where separate calculations must be performed for an entity or subgroup of entities within a country, the Summary for that country must be repeated to reflect the information on the relevant subgroups.
How to complete it
"RecJurCode"
When the GloBE Information Return is submitted in Norway, enter the country code “NO” for Norway. If the GloBE Information Return is intended for exchange with other countries, the “RecJurCode” element must also include the country codes for all countries that will receive information in the Summary. Summary is to be exchanged with all countries that has implemented QIIR and which the group chooses to rely on sentralised filing for. As Summary may contain information about multiple countries and subgroups requiring separate calculations, the country codes for all jurisdictions that should receive Summary must be repeated for each country added in the Summary.
When the Summary is intended for exchange with other countries, the value “GIR401” or “GIR402” must be entered in the FilingCERole element in Filing Info to indicate that the GloBE Information Return (GIR) is intended for exchanged. When the Summary is not intended to be exchanged with other countries, the value “GIR403” or “GIR404” must be entered in the FilingCERole element in Filing Info to indicate that the GloBE Information Return (GIR) is not intended to be exchanged from Norway.
"JurWithTaxingRights"
For each country and any subgroup, the Summary must include information on countries with taxing rights in the “JurWithTaxingRights” element. All countries with taxing rights must be reported, including where no top-up tax is calculated because the effective tax rate exceeds 15 percent or because a Safe Harbour rule, exclusion, or similar provision has been applied.
"Subgroup"
The “Subgroup” element must be used where the group contains entities or subgroups for which separate calculations must be performed. This applies to joint ventures and their subsidiaries, investment entities and insurance investment entities, minority-owned constituent entities and minority-owned subsidiaries, and stateless entities. Enter one of the predefined values “GIR1101” to ”GIR1106” in the “TypeofSubGroup” element, together with the TIN of the entity at the top of the ownership structure for each subgroup. Where separate calculations must be performed for an entity or subgroup of entities within a country, the Summary must be repeated to reflect information about the relevant subgroups in that country. Corresponding information about the subgroup must also be reported in the Jurisdiction Section.
"Safe Harbour"
The Summary must include information on any Safe Harbour rules applied by the entity submitting the GloBE Information Return. Information must also be provided about the use of the de minimis exclusion under section 5-5 of the Norwegian Global Minimum Tax Act.
When applying the permanent simplified calculation Safe Harbour rules for non-material constituent entities under sections 5-7-20 to 5-7-21 of the Global Minimum Tax Regulations, one of the predefined values "GIR1207” to ”GIR1209" must be entered to indicate which of the three tests has been applied.
When the reporting entity applies a Safe Harbour rule or the de minimis exclusion in a country or for a subgroup, top-up tax will normally be reduced to zero. In such cases, the reporting entity does not need to complete the entire Jurisdiction Section, only the part relating to “ETR Exception”.
- Where the entity has applied the permanent simplified calculation Safe Harbour and the simplified calculation does not apply to all entities located in the relevant country. In such cases, the reporting entity must complete the relevant parts of the Jurisdiction Section for the entities that are not covered by the simplified calculations.
- Where the entity has applied the permanent simplified calculation Safe Harbour, but additional top-up tax must be calculated. In such cases, the relevant elements in the Jurisdiction Section must also be completed.
- Where the entity has applied the routine profits test under the permanent simplified calculation Safe Harbour “GIR1209” or the transitional CBCR Safe Harbour “GIR1205”. In such cases, the reporting entity must also complete the “SubstanceExclusion” element in the Jurisdiction Section. When the “SubstanceExclusion” element is completed, the remaining validation elements in “Overall Computation” must also be completed with the value “0” to avoid XSD validation errors. This applies to the elements “FANIL”, “AdjustedFANIL”, “NetGlobeIncome”, “IncomeTaxExpense”, “ETRRate”, “TopUpTaxPercentage”, “ExcessProfits”, “TopUpTax”, and “ExcessNegTaxExpense”.
- Where the entity has applied the qualified domestic minimum top-up tax (QDMTT) Safe Harbour “GIR1202”. In such cases, the Jurisdiction Section must be completed in accordance with the national rules applicable in the Safe Harbour country. Note that the qualified domestic top-up tax Safe Harbour may also be used in combination with one of the other Safe Harbour rules. Where the entity has chosen to apply the qualified domestic top-up tax Safe Harbour in combination with another Safe Harbour rule, only the parts relating to those elections must be completed.
The qualified domestic minimum top-up tax (QDMTT) Safe Harbour “GIR1202” cannot be applied if one of the switch-off rules in section 5-7-10, subsection 3 of the Global Minimum Tax Regulations applies.
"DocSpec"
Enter the value "OECD1" in the “DocTypeINdic” element. The alternative predefined values must not be used when submitting the GloBE Information Return in Norway. The “DocRefId” element must be completed with a free-text value that provides a unique reference, for example "GIR2024NOII", where II is replaced with a new number for each part of the file.