Pillar Two Data

Input Catalog
January 2025

https://www.pwc.com/gx/en/services/tax/pillar-two-readiness.html
PwC’s Pillar Two Data Input Catalog January 2025

The evolving international tax landscape

1
Pillar Two brings unprecedented changes to the global
Executive tax system, impacting large multinational companies that
operate under the reformed international tax framework.
Pillar Two introduces a 15% global minimum Effective

summary
Tax Rate (ETR) for MNEs with consolidated revenue
over €750m - GloBE Rules. The regime discourages
shifting of profits by establishing a global minimum level
of taxation in relation to each country where an MNE
operates. The Model Rules released in December 2021
In June 2024, the OECD released the fourth set of
(and the accompanying Commentary published in March
Administrative Guidance (June Guidance) on the Global
2022) define the scope and key mechanics of the GloBE
Anti-Based Erosion Model Rules (Pillar Two). The June
Rules. Since the release of the Model Rules in 2021,
Guidance shed light on some areas where businesses
there have been four rounds of Administrative Guidance
and tax authorities have previously sought clarification
published, the first in February 2023, the second in July
and simplification: deferred tax liability (DTL) recapture,
2023, the third in December 2023, and the fourth in June
divergences between GloBE and accounting carrying
2024, which have helped to explain and provide clarity on
values, allocation of cross-border current taxes,
the Model Rules.
allocation of cross-border deferred taxes, allocation of
profits and taxes in structures including flow-through The GloBE Rules, which will impose a Top-up Tax for the
entities, and treatment of securitisation vehicles. The difference between the jurisdictional Pillar Two ETR and
June Guidance reaffirms the need for advance planning the 15% minimum rate, consist of (1) the income
around data identification, classification and utilisation for inclusion rule (IIR), which provides for the jurisdiction of
GloBE purposes. It is advisable for businesses to factor the group’s ultimate parent entity, or sometimes an
in the processes outlined in the June Guidance in the intermediate parent entity, to collect an allocation of the
expectation that jurisdictions will apply these rules both to top-up tax according to its ownership interest; and (2) the
IIR and domestic minimum top-up taxes. UTPR (formerly known as the ‘Undertaxed Payments
Rule’), which is intended to apply as a backstop if low-
The June Guidance follows previous OECD
taxed income is not fully collected under the IIR and
Administrative Guidance packages released in February
which can be applied in the jurisdictions of fellow group
2023, July 2023, and December 2023. For the guidance
members through denials of deductions as well as the
to become law, individual countries have been
imposition of charges. However, where a jurisdiction has
incorporating the OECD’s Administrative Guidance into
implemented a QDMTT, the top-up tax should first be
their Pillar Two legislation through various legislative
collected in that local country before applying the IIR or
vehicles. Following each set of the OECD Administrative
UTPR. The July 2023 Guidance provided a safe harbour
Guidance, PwC has updated the Data Input Catalog to
for qualifying QDMTTs that deems the Top-up Tax to
help prepare Multinational Enterprise Groups (MNEs) for
zero (for IIR or UTPR purposes) for a jurisdiction with a
the anticipated implementation of such regime. This
qualifying QDMTT as applied to the relevant MNE.
latest version of the Data Input Catalog has been
updated to incorporate the June Guidance and is Further, on October 3, 2023, the G20/OECD Inclusive
intended to provide an overview of the challenges and Framework (IF) on BEPS opened for signature by states,
complexities that MNEs will face upon the without reservations, a multilateral instrument (MLI) to
implementation of Pillar Two and be a detailed guide to implement the Pillar Two Subject to Tax Rule (STTR),
the information required for determining and computing which is a treaty-based rule intended to compliment the
amounts under the GloBE Rules. IIR and UTPR and adapt those rules for a treaty context.

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PwC’s Pillar Two Data Input Catalog January 2025

The STTR allows the source jurisdiction to “tax questions regarding how much simplification or
back” where income is covered in a defined benefit the safe harbour will provide. An MNE
category and subject to nominal corporate income Group must comply with the relevant filing
tax rates below the STTR minimum rate and requirements (yet to be agreed upon) to access
domestic taxing rights over that income have been these safe harbour rules, signifying that as a
ceded under a treaty. predicate for compliance, MNE Groups will have
Pillar Two has already been implemented by over to invest significant effort to obtain the data
35 jurisdictions taking effect in 2024, with over 50 regardless of whether the safe harbour can be
expected in 2025. As a result of these applied. The Safe Harbours and Penalty Relief
developments, most multinationals have at least document published in December of 2022, and
one constituent entity now subject to Pillar Two further detailed in the December 2023
legislation and the trend is likely to continue. Administrative Guidance, required that a Qualified
Differences and inconsistencies in the application CbCR be used, which is a more stringent standard
of QDMTT rules are evident among countries that than that required for CbCR today. Please refer to
have introduced these rules in 2024. As each the blog Transfer Pricing and the Pillar Two
implementing country adopts domestic legislation, Transitional CbCR Safe Harbor: Navigating
taxpayers can expect further variances as laws change: Steer your company through the effects of
change and evolve. country-by-country reporting for the latest insights
on CbCR.
The complexity, novelty, and uncertainty that Pillar
Two presents compounds the existing global Divergence in Pillar Two rules
compliance and regulatory challenges for MNEs.
Given the evolving regulatory landscape, global Divergence in rules as countries adopt and
compliance obligations are already overly implement domestic legislation appears inevitable.
complicated and demanding for tax departments The OECD’s public consultation document on Tax
and administrators. The overhaul of the Certainty for the GloBE Rules acknowledges this,
international tax framework is a massive stating:
undertaking for tax departments that are already The common approach under Pillar
spread thin and have limited resource capacity. Two contemplates that jurisdictions that wish to
Pillar Two’s global adoption, including the introduce the GloBE rules will implement and
The majority of businesses are anticipated divergence in local rules, poses
additional complexities that cannot be
apply their domestic law rules in a consistent and
coordinated manner. There is still a possibility that
looking to upgrade tax underestimated, undoubtedly requiring a global differences could arise in the interpretation or
network of international tax experts to help application of such rules among jurisdictions that
provision, tax compliance, navigate. To prepare for Pillar Two, MNEs will could give rise to divergent outcomes under the
need to focus on data, systems, technology, and GloBE rules.
and ERP/consolidation processes as the foundation for global and As countries are reaching agreement, the OECD
statutory compliance.
systems in preparation for Pillar Transitional Safe Harbour rules, relying on CbCR,
expects to be releasing further guidance on an
ongoing basis, generating future uncertainty about
Two. aim to limit the administrative and compliance divergence in GloBE Rules and creating significant
costs of conforming with the new international tax challenges in how taxpayers will incorporate each
framework and allow some corporations additional implementing jurisdiction’s unique adoption of the
time to fully prepare for the compliance and rules into their Pillar Two calculations.
*Source: PwC Tax Readiness Webcast: Pillar Two is here! How businesses reporting obligations. However, they also raise
are responding to the new GloBE rules (March 2024)
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PwC’s Pillar Two Data Input Catalog January 2025

Areas of divergence may include: Data strategy

• Effective dates of IIRs, UTPRs, and QDMTTs Identifying the data requirements and developing
• Mechanics of QDMTTs a comprehensive data strategy should be one of
the first steps that taxpayers take in preparation
• Potential variances in ordering rules for Pillar Two. Many of the data points may not be
• Computation and interaction with existing CFC readily available in current systems due to novelty
tax regimes and granularity (i.e. level of deconsolidation
• Implementation/application of the Transitional required at the constituent entity level) required
Safe Harbour (and later a more permanent Safe under Pillar Two. The data is likely to exist in the
Harbour) current state across several different source
systems (ERP, consolidation system, tax provision
• Other interpretations of IIR and UTPRs & compliance systems, HR systems, sales
As each implementing country adopts domestic systems, and other subledger systems) and is
legislation, taxpayers can expect further variances owned by different stakeholder groups in an
as laws change and evolve. Taxpayers can expect organization (Tax, Controllership, Legal, IT,
that the list above will continue to expand with People, and FP&A). The variety of data sources
Pillar Two global implementation. owned by a diverse group of stakeholders makes
the collection and synthesization of the data
Quantitative analysis tremendously challenging. Early cross-functional
To be successful in a global environment with engagement is critical to ensure that the
disparate Pillar Two local rules, MNEs will need to appropriate data and system owners are aware of
employ an agile data model and calculation what will be required under Pillar Two, why it’s
engine, configured to support the inconsistent and important, and how it may impact them going
unique adoption of Pillar Two rules around the forward.
world and allow for flexibility as those rules An MNE will need to establish a cohesive,
continue to evolve. Multiple different variations and efficient, and automated process to extract,
interpretations of local rules will require an cleanse, and organize the data. Companies
iterative modeling process for Pillar Two should be thinking about developing a data model
calculations. A calculation engine should be that allows them to identify how this information
compliance-grade and also have capacity to drives Pillar Two calculations and the potential
perform at volume given the exhaustive data ETR impact. This is arguably one of the most
requirements, intra-data relationships, and rules
ordering. While a centralized calculation engine
demanding and daunting aspects of ensuring
readiness for Pillar Two and not something
Resource constraints in
will be imperative in a Pillar Two environment, organizations should wait to explore. reporting and compliance
sourcing the underlying data should be an MNE’s
top priority for Pillar Two readiness. are viewed as the biggest
challenge for businesses
preparing for Pillar Two.
*Source: PwC Tax Readiness Webcast: Pillar Two is here! How
businesses are responding to the new GloBE rules (March 2024)

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PwC’s Pillar Two Data Input Catalog January 2025

29% of businesses are

undecided on the delivery model
they will implement to comply
with Pillar Two (e.g. outsourcing,
insourcing, co-sourcing).
*Source: PwC Tax Readiness Webcast: How Pillar Two and the EU FSR
impact multinational entities (July 2024)

Operational readiness
Inherently tied to a successful data strategy,
Pillar Two will likely require a go-forward Pillar Two will have a pervasive impact on an
organizational transformation rooted in organization’s financial operating model
systems and processes that can sustain requiring early stakeholder engagement and
reporting and compliance requirements upon substantial budget and resource allocation to
enactment. A current state analysis can help address the multitude of challenges.
take inventory of the underlying data Organizations must ask themselves if their
architecture, system landscape, existing current data model, systems, technology, and
processes, technology sufficiency, and processes can support the requirements
resource capacity, and identify any gaps. The introduced by this new international tax
future state for Pillar Two should include a framework. The complexity of Pillar Two and
comprehensive data strategy, technology- the level of effort for global compliance cannot
enabled processes to facilitate the efficient flow be underestimated.
of information, enhancements or
implementation of new technology, a
calculation engine, resource model, connected
compliance plan, and effective governance.
Once the gaps between the current and future
state have been identified, they should be
leveraged to construct a roadmap for Pillar
Two implementation.

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PwC’s Pillar Two Data Input Catalog January 2025

2 A connected
approach The Data Input Catalog defines the data requirements for Pillar Two, giving MNEs a
comprehensive understanding of the amount of work that lies ahead of them and
can help MNEs anticipate the unique challenges they will face. Acting as the
foundation to develop an extensive data strategy, assess operational preparedness,
Taxpayers will need to take a holistic approach to determine how data will be or determine a modeling approach, PwC’s Data Input Catalog is the core to Pillar
sourced, processed, calculated, and reported for Pillar Two compliance. Every Two readiness. As part of a connected approach, PwC has developed a dynamic
company will be unique in the challenges they will face, and thus, there is no one- Pillar Two Questionnaire within Sightline based on the Data Input Catalog designed
size-fits-all solution that can address the Pillar Two challenges and complexities. to efficiently narrow down the scope of client’s data for Pillar Two requirements and
MNEs will need to customize an approach centered around foundational building collect relevant entity level data that is not centrally available.
blocks – resources, data requirements, existing enterprise systems, and other Our flexible and technology-enabled Connected Compliance approach ensures that
technology (e.g. tax provision software). A connected end-to-end process needs to we can support companies with preparing and filing the tax returns required today,
be designed to support the Pillar Two operating model and compliance process, while leveraging the same data to plan for the impact of Pillar Two and meet the
ideally leveraging as much from the current data and technology ecosystem as filing requirements in the future. All as part of one ‘Connected approach’, using our
possible. The Data Input Catalog is foundational to PwC’s end-to-end process for ‘Connected technology Platform’ and supported by one ‘Connected team’, we
Pillar Two. achieve ‘Connected Outcomes’ to meet the requirements of today and tomorrow.

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PwC’s Pillar Two Data Input Catalog January 2025
81% of companies have focused
on operational readiness in
3 Data Input preparation for Pillar Two.

Catalog *Source: PwC Tax Readiness Webcast: New Year's Resolution - Prepare for
Pillar Two! (January 2024)

In December 2022, the OECD released several Pillar

Two guidance and consultation documents that shed light
on the practical application of the GloBE Rules, including
the GIR. The GIR was finalized in July 2023 following the
public consultation in March 2023. In July 2024, the
OECD released a draft GIR XML Schema and User
Guide, which is designed to both facilitate domestic GIR
filings, wherever appropriate, and to be the technical
format for exchanging GIR information between tax
administrations. The draft guide was open for public
consultation through August 2024.
Annex A1 of the GIR represents a compilation of Pillar PwC’s Data Input Catalog provides an
Two data points by constituent entity, exacerbating the additional level of detail for specific
intricacy of Pillar Two due to the level of granularity adjustments to determine the computation of
required. The 24 data points included in the GIR to Adjusted Covered Taxes and GloBE Income
determine GloBE Income (Loss) means that if an MNE – how the adjustments are determined and
has 400 constituent entities, that’s almost 10,000 data calculated – which is not included in GIR
points that must be sourced and ultimately put on a form. Annex A1. In addition, the qualitative data
This is assuming that a constituent entity only operates in points included in PwC’s Data Input Catalog
PwC's Data Input Catalog only includes the inputs
a single jurisdiction, and it is also noteworthy that the are intentionally different from GIR Annex A1.
required for Pillar Two, which can then be efficiently
obligation to prepare the GIR is separate from any local There is familiarity with the qualitative data
sourced to PwC’s Pillar Two Engine. The Pillar Two
tax return requirements. Implementing jurisdictions will in points included in PwC’s Data Input Catalog,
calculations for all jurisdictions and constituent
many cases also amend the local corporate income tax facilitating an easier and simpler data-
entities are then performed in the Pillar Two Engine.
return to request additional GloBE information pertinent gathering process. These qualitative data
On the contrary, the GIR Annex A1 includes all data
to that jurisdiction, and MNE Groups will need to comply points are reconciled to GIR Annex A1 as
points, calculated fields, aggregations, etc. making it
separately with these local requirements. ‘Master Data’. PwC’s Pillar Two Engine, a
difficult for clients to distinguish between source and
centralized calculation engine with graphical
Understandably, MNEs may be overwhelmed with the calculated data.
databases, is configured to support the
amount of work ahead of them. To provide an additional
inconsistent and unique adoption of Pillar
layer to the data requirements introduced by the OECD in
Two rules in every adopting country. With
GIR Annex A1, PwC has developed a Data Input Catalog
many output and reporting capabilities,
for companies to leverage in developing a Pillar Two data
PwC’s Pillar Two Engine is designed to
strategy.
support the many regulatory and compliance
requirements.

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PwC’s Pillar Two Data Input Catalog January 2025

4 How PwC
can help
PwC professionals can help provide additional
explanations, user stories and practical application of
Assess Report Comply
each data requirement that assist clients in navigating the
complexity and relevancy of the rules from PwC’s Data PwC helps assess and model the PwC can enhance reporting and PwC can help meet ongoing
likely financial and operational data analytics capabilities, including: reporting and compliance
Input Catalog. Contact a PwC professional for a deeper consequences of Pillar Two, including: obligations, including:
understanding of the Pillar Two data requirements and
how PwC’s Data Input Catalog can help determine how • Evaluating data accessibility and • Detailed modeling to provide the • Supporting the development and
quality, enterprise and tax system data for financial disclosures. configuration of modeling and
to access the financial data needed to comply, identify configuration gaps and compliance solutions using your
• Validating deferred balances
gaps in the data needed for reporting, and model Pillar opportunities for remediation. existing systems or your
ahead of the first Pillar Two
Two impact using our centralized calculation engine. • Understanding how the various reporting period. internally developed solution.
More broadly, PwC professionals can help assess and data requirements map into the • Updating ERP/CPM processes • Utilizing PwC’s Pillar Two Engine
model the likely financial and operational consequences calculation itself. and cloud data solutions. to help reduce the time and cost
associated with your future
of Pillar Two, including re-evaluating operations given the • Standing up new processes that • Reviewing the existing tax
will be required under Pillar Two. reporting and compliance
anticipated law changes in many countries. reporting process and use of obligations.
• Analyzing the potential benefit of technology to
making certain elections under automate/streamline. • Documenting Pillar Two related
Pillar Two. processes and controls to align
• Consulting on tax accounting with tax governance frameworks.
• Modeling to understand both Pillar treatment, reviewing disclosures.
Two financial impact and process • Determining and consulting on
impact on key jurisdictions. how Pillar Two fits into the wider
compliance and reporting
• Assessing whether operational or process to increase efficiencies
structural changes may be and insights, leveraging
beneficial. connected data.
• Aligning stakeholders and
determining operating model
impacts.
• Providing tax policy background to
contextualize the data
requirements.
Learn more:
• Advising on the potential tax policy
direction of travel for future rules.
Tax Policy and Administration
• Suggesting input into the process
to improve rules.
International Tax Services

Tax Reporting and Strategy

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 PwC’s Pillar Two Data Input Catalog January 2025

5 Key
contacts

Doug McHoney Will Morris Anthony Sciarra Matthew Ryan

International Tax Services Global Tax Policy Connected Tax Compliance Tax Partner
Global Leader Leader US Leader International Tax Services
PwC PwC PwC US PwC UK
douglas.mchoney@pwc.com william.h.morris@pwc.com anthony.sciarra@pwc.com matthew.a.ryan@pwc.com
+1 314-749-7824 +1 202-213-2372 +1 646-599-3811 +44 7718-981211

Jesse Kavanagh Jorgen Broothaers Jurriaan Weerman Erin Callanan

Tax Partner Tax Partner Tax Partner Tax Partner
Tax Reporting & Strategy Tax Reporting & Strategy Tax Reporting & Strategy Industry Tax Practice
PwC Hong Kong PwC Belgium PwC Netherlands PwC US
jesse.kavanagh@hk.pwc.com jorgen.broothaers@pwc.com jurriaan.weerman@pwc.com erin.callanan@pwc.com
+852 2289-1100 +32 473-91-02-06 +31 88-792-5086 +1 215-796-1018

Pieter Deré Steven Kohart Philip Ramstetter Katherine Miller

Tax Partner Tax Principal Tax Partner Tax Director
International Tax Services International Tax Services International Tax Services Tax Reporting & Strategy
PwC Belgium PwC US PwC US PwC US
pieter.dere@pwc.com steven.p.kohart@pwc.com philip.s.ramstetter@pwc.com katherine.miller@pwc.com
+32 498-48-95-11 +1 203-517-6174 +1 513-254-6201 +1 203-512-6473

Patrick Coughlin
Tax Director
Quantitative Solutions &
Technology
PwC US
patrick.coughlin@pwc.com
+1 708-218-8172

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PwC’s Pillar Two Data Input Catalog January 2025

6 Data Input
Catalog

Data Input Catalog

11 Appendix A
Constituent Entities
14 Appendix B
Computation of GloBE Income or Loss
21 Appendix C
Computation of Adjusted Covered Taxes
28 Appendix D
Share & Asset Transactions
30 Appendix E
Substance-based Income Exclusion
32 Appendix F
Allocation of Taxes
34 Appendix G
Transitional Safe Harbours
36 Appendix H
Legend

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PwC’s Pillar Two Data Input Catalog January 2025

Appendix A
Constituent Entities

11
PwC’s Pillar Two Data Input Catalog January 2025 Appendix A | Constituent Entities

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Constituent Entities - Group Information
1.001 List of Constituent Entities (including Permanent Establishments and any entities that may be Data Point Legal/Tax MR 1.3 Master Data
excluded for GloBE purposes)
1.002 List of entities held for sale or reported in discontinued operations for the fiscal year Data Point Legal/Tax MR 5.3.4.47
1.003 Direct ownership percentage of each CE held within the group by other Constituent Entities Data Point Legal/Tax MR 8.1.4(b) 1.3.3.7, 1.3.3.8
(UPE/POPE/IPE)
1.004 Direct ownership percentage of each CE held outside the group (3rd party or non-Constituent Data Point Legal/Tax MR 8.1.4(b)
Entity)
1.005 Controlling interests (in %) of the Ultimate Parent Entity in each Constituent Entity (automated in Calculation Legal/Tax MR 8.1.4(b) 1.3.2.1.10
Pillar Two Engine based on direct ownership percentages above)
1.006 Consolidated Financial Statements of the UPE (type) Informational Finance MR 3.1.2 1.2.2.1
1.007 Financial Accounting standard(s) used for the CFS of the UPE Informational Finance MR 3.1.2 1.2.2.2, 3.3.4.1
1.008 Group reporting currency (consolidated financial statements) Informational Finance July 2023 AG 1.6 - 1.15
1.009 Designated local entity for each jurisdiction Informational Legal/Tax MR 8.1
1.010 List of fiscal unity/tax consolidation groups within MNE group Data Point Legal/Tax MR 3.2.4(b)
1.011 List of CFC regimes within MNE group (including blended CFC regimes) Data Point Legal/Tax MR 4.3.2, 10.1
1.012 List of Main Entities that own a PE/branch/disregarded entity/flow-through Data Point Legal/Tax MR 3.4, 3.5
1.013 Election - De Minimis Exclusion (by Jurisdiction) Election Tax MR 5.5.1 2.2.2
1.014 Average December FX rate from previous year as quoted by the European Central Bank (ECB) Data Point Finance/Tax MR 4.6, 5.5.1
1.015 Nominal statutory tax rate for UPE jurisdiction Data Point Tax MR 7.1.1(a) 2.2.1.3.b.1
Constituent Entities - Entity Information
1.016 Tax identification number for each Constituent Entity Data Point Legal/Tax MR 8.1.4(a) Master Data
1.017 Legal form Data Point Legal/Tax MR 8.1, 10.2 Master Data
1.018 Location for each Constituent Entity Data Point Legal/Tax MR 10.3 Master Data
1.019 Accounting functional currency Data Point Legal/Tax MR 3.2.1(f) 1.2.2.2
1.020 Tax functional currency Data Point Legal/Tax MR 3.2.1(f) 1.2.2.3
1.021 Third currency of any financial/operation transactions (if applicable) Data Point Legal/Tax MR 2.34, 3.2.1(f)

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PwC’s Pillar Two Data Input Catalog January 2025 Appendix A | Constituent Entities

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
1.022 Status for GloBE purposes (Tax qualification for each Constituent Entity): Data Point Legal/Tax MR 10.1, 10.2, 1.3.1.6
• Incorporated entity
• Permanent establishment February 2023 AG 2.9
• Hybrid entity par 57.8, 2022 SH 6.1
• Reverse hybrid
• Tax transparent entity December 2023 AG 6.2
• Qualified ownership interest (tax transparent entity) – NMCE
• Investment entity
• Insurance investment entity June 2024 AG 5.2.2.33
• Governmental entity - Flow-Through UPE
• International organization June 2024 AG 5.5 -
• Non-profit organization Hybrid Entities
• Pension fund June 2024 AG 6.1.1.3 -
• Joint Venture Securitisation Vehicles
• Tax Neutral UPEs (for Transitional Safe Harbour)
• Non-Material Constituent Entity (for Transitional Safe Harbour)
• Excluded Entities (for Transitional Safe Harbours)
• Flow-Through UPE/Reference Entity
• Securitisation Entity
1.023 Election - Investment Entity Tax Transparency Election Tax MR 7.5 3.2.4.3.3.f
1.024 Election - Treatment of an Excluded Entity as Constituent Entity Election Tax MR 1.5.3 3.2.4.3.3.c
1.025 If the entity is transferred during the current year, number of days/months the financials are Data Point Legal/Tax MR 6.2 1.3.3
included (and where) within the structure
1.026 Current tax rate Data Point Tax MR 4.4.1 2.2.1.3.b.1
1.027 Deferred tax rate Data Point Tax MR 4.4.1
1.028 GloBE Revenue (after GloBE adjustments and after consolidation adjustments attributable to Calculation Tax MR 1.1, 5.5.1-5.5.3, 6.1 2.2.2.1.2
intra-group transactions) for de minimis test
1.029 Acceptable or Authorised Financial Accounting Standard (if different than UPE) Informational Finance MR 3.1.3 3.2.4.6.2
1.030 Transition Year Informational Tax MR 9.1, July 2023 AG 4 2.3.1
paragraph 45-54
1.031 Fiscal Year-End Date (if not Calendar Year-end) Data Point Finance/Tax MR 8.1.6 1.2.1.3

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PwC’s Pillar Two Data Input Catalog January 2025

Appendix B
Computation of
GloBE Income or
Loss

14
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of GloBE Income or Loss - Allocation of GloBE Income Between Constituent Entities
2.001 Financial Accounting Net Income or Loss (before any consolidation adjustments for intra-group Data Point Finance/ MR 3.1 3.2.4.1.a
transactions). Profit After Tax as recorded in the legal entity accounts under group accounting Controllership
standard.
2.002 Loss incurred at PE in the current year that is deductible at Main Entity Data Point Finance/ MR 3.4.5 3.2.4.1.b
Controllership
2.003 Loss incurred at PE in a prior year that was deducted at Main Entity Data Point Finance/ MR 3.4.5 3.2.4.1.b
Controllership
2.004 Amount of GloBE Income recorded in a PE that is allocated to the ME Data Point Finance/ MR 3.4.5 3.2.4.1.b
Controllership
2.005 Items booked in one entity (e.g., Main Entity, group/consolidated financial accounts, UPE) that are Data Point Finance/ MR 3.4, 3.5 3.2.4.1.b.7
related to and can reliably be traced to other CEs Controllership
2.006 Profit and loss adjustments related to intra-group transactions (consolidation/elimination Data Point Finance/ MR 3.1.2
adjustments) unless consolidation election is made Controllership
Computation of GloBE Income or Loss - International Shipping Income Exclusion
2.007 International Shipping Income (ISI) Calculation Finance/ MR 3.3.2 3.2.4.4.a.5
Controllership
2.008 ISI Revenue - Freight including Slot Chartering Data Point Finance/ MR 3.3.2(a)/(b) 3.2.4.4.a.5
Controllership
2.009 ISI Revenue - Time or Voyage Charter Data Point Finance/ MR 3.3.2(c) 3.2.4.4.a.5
Controllership
2.010 ISI Revenue - bareboat Charter Data Point Finance/ MR 3.3.2(d) 3.2.4.4.a.5
Controllership
2.011 ISI Revenue - Participation in International Operating Agency Data Point Finance/ MR 3.3.2(e) 3.2.4.4.a.5
Controllership
2.012 ISI Revenue - Participation in Joint Business Data Point Finance/ MR 3.3.2(e) 3.2.4.4.a.5
Controllership
2.013 ISI Revenue - Participation in Pool Data Point Finance/ MR 3.3.2(e) 3.2.4.4.a.5
Controllership
2.014 ISI Revenue - Sale of Ship Data Point Finance/ MR 3.3.2(f) 3.2.4.4.a.5
Controllership
2.015 Non-qualifying shipping income (NQSI) Revenue - Sale of Ship Data Point Finance/ MR 3.3.2(f)
Controllership
2.016 Qualified Ancillary International Shipping Income (QAISI) Calculation Finance/ MR 3.3.3 3.2.4.4.a.9
Controllership
2.017 QAISI Revenue - Bareboat Charter Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership
2.018 NQSI Revenue - Bareboat Charter Data Point Finance/ MR 3.3.2
Controllership
2.019 QAISI Revenue - Ticket Sales for International Voyage (Domestic Leg) Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership
2.020 QAISI Revenue - Leasing or Short-term Storage of Containers Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership
2.021 QAISI Revenue - Detention Charges Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership

15
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
2.022 QAISI Revenue - Services to Other Shipping Enterprises Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership
2.023 QAISI Revenue - Investment Income Data Point Finance/ MR 3.3.2 3.2.4.4.a.9
Controllership
2.024 NQSI Revenue - Inland Component Data Point Finance/ MR 3.3.5
Controllership
2.025 Inland Component Reclass Data Point Finance/ MR 3.3.5
Controllership
2.026 Non-Shipping Passive Revenue Data Point Finance/ MR 3.3.5
Controllership
2.027 Non-Shipping Trade Revenue Data Point Finance/ MR 3.3.5
Controllership
2.028 Other Shipping Expense for Apportionment (All) Data Point Finance/ MR 3.3.5
Controllership
2.029 Shipping Expense for Apportionment (ISI/QAISI/NQSI) Calculation Finance/ MR 3.3.5
Controllership
2.030 ISI - Shipping Expense Allocated Calculation Finance/ MR 3.3.5 3.2.4.4.a.4
Controllership
2.031 QAISI - Shipping Expense Allocated Calculation Finance/ MR 3.3.5 3.2.4.4.a.8
Controllership
2.032 NQSI - Shipping Expense Allocated Calculation Finance/ MR 3.3.5
Controllership
2.033 Non-Shipping Trade Expense Allocated Calculation Finance/ MR 3.3.5
Controllership
2.034 Non-Shipping Passive Expense Allocated Calculation Finance/ MR 3.3.5
Controllership
2.035 Location of strategic and commercial management of ships with ISI & QAISI Data Point Finance/ MR 3.3.6
Controllership
Computation of GloBE Income or Loss - Net Tax Expense Adjustment
2.036 Covered taxes accrued as an expense (above the tax line) Data Point Tax MR 4.1.2 3.2.4.2.a.3.a
2.037 Current taxes included in income tax expense Data Point Tax MR 4.1.1 3.2.4.2.a.3.r
2.038 Deferred taxes included in income tax expense Data Point Tax MR 4.1.1, 4.4 3.2.4.2.a.3.r
2.039 Interest related to Covered Taxes Data Point Tax MR 4.2.1
2.040 Penalties related to Covered Taxes Data Point Tax MR 4.2.1
2.041 Taxes arising pursuant to the GloBE rules ([Q]DMTT/IIR/UTPR) that are included as an expense Data Point Tax MR 4.2.2

June 2024 AG
5.6.2.100

16
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of GloBE Income or Loss - Taxes on Distributions
2.042 Disqualified refundable imputation taxes accrued as an expense Data Point Tax MR 4.2.2
Computation of GloBE Income or Loss - Excluded Dividends
2.043 Excluded Dividends Calculation Finance/Tax MR 3.2.1(b) 3.2.4.1.a.3.b
2.044 List of Non-Portfolio Shareholdings Data Point Finance/Tax MR 3.2.1(b)
2.045 List of Short-Term Portfolio Shareholdings Data Point Finance/Tax MR 3.2.1(b)
2.046 List of Non-Short Term Portfolio Shareholdings Data Point Finance/Tax MR 3.2.1(b)
2.047 Election - Include Portfolio Shareholdings Dividend Income Election Finance/Tax February 2023 AG 3.5 3.2.4.3.3.d
2.048 Dividends from a Financial Instrument that is treated differently by the issuer and the holder Data Point Finance/Tax February 2023 AG 2.3
2.049 Dividends from a Compound Financial Instrument Data Point Finance/Tax February 2023 AG 2.3
Computation of GloBE Income or Loss - Election - Equity Investment Inclusion
2.050 Gains and losses from changes in fair value of an Ownership Interest; except for a disposition of a Data Point Finance/ MR 3.2.1(c) 3.2.1.1.2.c
Portfolio Shareholding Controllership
2.051 Profit or loss in respect of an Ownership Interest included under the equity method of accounting; Data Point Finance/ MR 3.2.1(c) 3.2.1.1.2.c
except for a disposition of a Portfolio Shareholding Controllership
2.052 Gains and losses from disposition of an Ownership Interest, except for a disposition of a Portfolio Data Point Finance/ MR 3.2.1(c) 3.2.1.1.2.c
Shareholding Controllership
2.053 Election - Equity Investment Inclusion Election Election Finance/ February 2023 AG 3.2.3.1.a.3.e
Controllership 2.9.2
Computation of GloBE Income or Loss - Election - Equity Investment Foreign Exchange Hedge
2.054 Profit or loss recorded in the P&L from instruments that hedge FX risk from net investments in Data Point Finance/ February 2023 AG 2.2, 3.2.4.3.3.e
foreign operations Controllership MR 3.2.1(c)
Computation of GloBE Income or Loss - Revaluation Method Gain or Loss
2.055 Revaluation Method Gain or Loss (changes in value of carrying value of property, plant and Data Point Finance/ MR 3.2.1(d) 3.2.4.1.a.3.d
equipment included in OCI) Controllership
Computation of GloBE Income or Loss - Election - Realisation Principle
2.056 Election - Use of the realisation method in lieu of fair value or impairment accounting Election Finance/Tax MR 3.2.5 3.2.3.1.a.3.g
2.057 Fair value revaluation gains or loss recorded in P&L Data Point Finance/ MR 3.2.5 3.2.4.1.a.3.o
Controllership
2.058 Difference in P&L depreciation between Fair Value or Impairment accounting and the Realisation Calculation Finance/ MR 3.2.5 3.2.4.1.a.3.o
Method if the Realisation Method is elected Controllership
2.059 Realized gain or loss upon disposition of any asset subject to the realisation method election Calculation Finance/ MR 3.2.5 3.2.4.1.a.3.o
Controllership
2.060 Difference between the fair value and the carrying value of assets/liabilities in the case that the Calculation Finance/ MR 3.2.5(c)
Realisation Method election is revoked Controllership
2.061 Fair value revaluation gains or losses recorded in OCI in the case that the Realisation Method Data Point Finance/ MR 3.2.1
election is not made Controllership
2.062 Adjusted depreciation on revalued assets in the case that the Realisation Method election is not Calculation Finance/ MR 3.2.1
made Controllership
Computation of GloBE Income or Loss - Election - Fair Value Recognition
2.063 Election - Fair value recognition (where domestic tax rules require or permit recognising assets Election Finance/ MR 6.3.4 3.2.4.3.3.h
and liabilities at fair market value, such CEs may make an election to reflect the domestic tax Controllership
treatment)

17
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of GloBE Income or Loss - Asymmetric Foreign Currency Gains or Losses
2.064 Asymmetric Foreign Currency Gains or Losses Informational Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
2.065 FX included in taxable income and caused by difference between tax and accounting functional Data Point Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
currency
2.066 FX included in accounting income and caused by the difference between tax and accounting Data Point Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
functional currency
2.067 FX fluctuation between a (third) foreign currency and the accounting functional currency Calculation Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
2.068 FX fluctuation between a (third) foreign currency and the tax functional currency Calculation Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
2.069 FX result on PE recorded in the main entity because the accounting currency of the PE differs Calculation Finance/Tax MR 3.2.1(f), 10.1 3.2.4.1.a.3.f
from the tax functional currency of the main entity and there is a taxable FX result on the PE
Computation of GloBE Income or Loss - Policy Disallowed Expenses
2.070 Expenses accrued by the Constituent Entity for illegal payments, including bribes and kickbacks Data Point Finance/ MR 3.2.1(g), 10.1 3.2.4.1.a.3.g
Controllership
2.071 Expenses accrued by the Constituent Entity for fines and penalties that equal or exceed EUR Data Point Finance/ MR 3.2.1(g), 10.1 3.2.4.1.a.3.g
50,000 (or an equivalent amount in the functional currency in which the Constituent Entity’s Controllership
Financial Accounting Net Income or Loss was calculated)
Computation of GloBE Income or Loss - Prior Period Errors and Changes in Accounting Principles
2.072 Prior Period Errors and Changes in Accounting Principles Informational Finance/Tax MR 3.2.1(h) 3.2.4.1.a.3.h,
3.2.4.1.a.3.i
Computation of GloBE Income or Loss - Election - Immaterial Decrease in Covered Tax
2.073 Election - Immaterial Decrease in Covered Tax Election (relates to Previous Fiscal Year Election Finance/Tax MR 4.6.1 3.2.3.1.a.1.b
Adjustments)
2.074 All changes in the opening equity at the beginning of the Fiscal Year of a Constituent Entity Data Point Finance/Tax MR 4.6.1 3.2.3.1.a.1.b
attributable to an error or change that lead to a corresponding decrease of Covered Taxes in a
previous Fiscal Year of 1M EUR or more (per jurisdiction)
Computation of GloBE Income or Loss - Accrued Pension Expense
2.075 Accrued Pension Expense Data Point Finance/ MR 3.2.1(i) 3.2.4.1.a.3.j
Controllership
2.076 Amount of pension liability expense included in the Financial Accounting Net Income or Loss Data Point Finance/ MR 3.2.1 (i),10.1.1 3.2.1.1.2.j
Controllership
2.077 Amount contributed to a Pension Fund for the Fiscal Year Data Point Finance/ MR 3.2.1 (i),10.1.1 3.2.1.1.2.j
Controllership
2.078 Refund of pension fund surplus to the sponsor Data Point Finance/ MR 3.2.1 (i),10.1.1 3.2.1.1.2.j
Controllership
Computation of GloBE Income or Loss - Income Reallocated under Pillar One
2.079 Income reallocated in the context of Pillar One Data Point Tax MR Commentary 4.2.29
Computation of GloBE Income or Loss - Arm's Length Principle
2.080 Pricing on transactions between Constituent Entities located in different jurisdictions to ensure Informational Finance/Tax MR 3.2.3 3.2.1.1.2.m
that they are recorded at arms length 3.2.4.1.a.3.m
2.081 Transactions between Constituent Entities located in the same jurisdiction resulting in a loss to Data Point Finance/Tax MR 3.2.3 3.2.1.1.2.m
the transferor. 3.2.4.1.a.3.m
2.082 Transactions between Constituent Entities and Minority-owned Constituent Entities/MOCE Group Data Point Finance/Tax MR 3.2.3, 5.1, 5..2, 5.6 3.2.1.1.2.m
entities 3.2.4.1.a.3.m

18
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
2.083 Transactions between Constituent Entities and JVs/JV Group entities Data Point Finance/Tax MR 3.2.3, 5.1, 5..2, 6.4 3.2.1.1.2.m
3.2.4.1.a.3.m
Computation of GloBE Income or Loss - Qualified Refundable Tax Credits & Non-Qualifying Tax Credits
2.084 Qualified Refundable Tax Credits & non-qualifying tax credits Data Point Tax MR 3.2.4 3.2.4.1.a.3.n
2.085 Qualified Refundable Tax Credits included in Current Tax Data Point Tax MR 3.2.4
2.086 Non-Qualified Refundable Tax Credit or non-refundable credit included in PBT Data Point Tax MR 3.2.4
2.087 Marketable Transferable Tax Credits included in Current Tax Data Point Tax July 2023 AG 2.34 -
2.39
2.088 Non-Marketable Transferable Tax Credits included in PBT Data Point Tax MR 3.2.4 3.2.1.2.a.2.g
Computation of GloBE Income or Loss - Intra Group Transactions
2.089 Low-Tax Entity intra group financing arrangement Calculation Tax MR 3.2.7 3.2.4.1.a.3.q
Computation of GloBE Income or Loss - Election - Stock-Based Compensation
2.090 Election - Stock-Based Compensation Election Finance/Tax MR 3.2.2 3.2.3.1.a.3.f
2.091 Stock based compensation expense included in Financial Accounting Net Income or Loss Data Point Finance/Tax MR 3.2.2 3.2.4.1.a.3.l
2.092 Stock based compensation deducted for tax purposes Data Point Finance/Tax MR 3.2.2 3.2.4.1.a.3.l
2.093 Cross-charges received from CEs that incurred the costs at grant and charges out the costs at Data Point Finance/Tax MR 3.2.2
vest in the case that the Stock Based Compensation election is made
2.094 Cross-charges paid to CEs that have incurred the cost at grant in the case that the Stock Based Data Point Finance/Tax MR 3.2.2
Compensation election is not made
2.095 Previously deducted stock-based compensation expense of options that have been expired Calculation Finance/Tax MR 3.2.2
without exercise
Computation of GloBE Income or Loss - Election - Aggregate Asset Gain
2.096 Election - Aggregate Asset Gain Election Finance/Tax MR 3.2.6 3.2.3.1.a.1.a
2.097 Aggregate Asset Gain spread evenly across look-back period Data Point Finance/Tax MR 3.2.6 3.2.4.1.a.3.p
Computation of GloBE Income or Loss - Election - Jurisdictional Consolidation Election/Tax Consolidation Group Adjustments
2.098 Election - Jurisdictional Consolidation Election/Tax Consolidation Group Adjustments Election Finance/Tax MR 3.2.8 3.2.3.1.a (2h)
Computation of GloBE Income or Loss - Election - Debt Release Exclusion
2.099 Election - Debt Release Exclusion Election Finance/ February 2023 AG 2.4 3.2.4.3.2.a
Controllership
2.100 Debt release included in the Financial Accounting Net Income Data Point Finance/ February 2023 AG 3.2.4.1.a.3.k
Controllership 2.4.3
Computation of GloBE Income or Loss - Insurance Company Specific Deductions
2.101 Insurance company specific deductions/additions Calculation Finance/Tax MR 3.2.9 3.2.1.1.2.s,
3.2.4.1.a.3.s
2.102 Amounts charged to policyholders for taxes paid by the insurance company in respect of returns Data Point Finance/Tax MR 3.2.9
to the policyholders
2.103 Any returns to policyholders not included in Financial Accounting Net Income or Loss to the Data Point Finance/Tax MR 3.2.9
extent the corresponding increase or decrease in liability to the policyholders is reflected in its
Financial Accounting Net Income or Loss
2.104 Movement in insurance company's reserves related to Excluded Dividends Data Point Finance/Tax February 2023 AG
3.4.1
2.105 Movement in insurance company's reserves related to Excluded Equity Gain or Loss Data Point Finance/Tax February 2023 AG
3.4.2

19
PwC’s Pillar Two Data Input Catalog January 2025 Appendix B | Computation of GloBE Income or Loss

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of GloBE Income or Loss - Tier One Capital
2.106 Equity increase/decrease attributable to distributions paid or payable in respect of Additional Tier Data Point Finance/Tax MR 3.2.10 3.2.1.1.2.t, 3.2.4.1.a.3.t
One Capital and Restricted Tier One Capital
2.107 Additional Tier One Capital/Restricted Tier One Capital distributions paid or payable Data Point Finance/Tax MR 3.2.10 3.2.1.1.2.t, 3.2.4.1.a.3.t
2.108 Amounts recognized as an increase to the equity Data Point Finance/Tax MR 3.2.10, 5.5.3 3.2.1.1.2.t, 3.2.4.1.a.3.t
2.109 Amounts recognized as an expense Data Point Finance/Tax MR 3.2.10, 5.5.3 3.2.1.1.2.t, 3.2.4.1.a.3.t
2.110 PLACEHOLDER - Conversion or write-off in the books of the Issuer/Subscriber Data Point Finance/Tax MR 3.2.10
Computation of GloBE Income or Loss - Tax Neutrality and Distribution Regimes
2.111 Flow-through Entity reduction (UPE) Data Point Tax MR 7.1.1 3.2.4.1.a.3.v
2.112 Deductible Dividend Regime reduction (UPE) Data Point Tax MR 7.2.1 3.2.4.1.a.3.w
2.113 Election - Deemed Distribution Tax Election for Eligible Distribution Tax Systems Election Tax MR 7.3 3.2.3.2.1
Computation of GloBE Income or Loss - Election - Taxable Distribution Method
2.114 Election - Taxable Distribution Method Election Tax MR 7.6 3.2.4.3.3.g, 3.2.1.1.2.x
2.115 Actual and deemed distributions made to the CE owner of an Investment Entity in the case that Data Point Tax MR 7.6.1, AG 3.8.1 3.2.4.3.3.g, 3.2.1.1.2.x
the Investment Entity Taxable Distribution Method Election is made
2.116 Creditable tax paid by the CE owner on its share of the income distributed by the Investment Data Point Tax MR 7.6 3.2.4.3.3.g, 3.2.1.1.2.x
Entity in the case that the Investment Entity Taxable Distribution Method Election is made
2.117 Distributions made by the Investment Entity in the case that the Investment Entity Taxable Data Point Tax MR 7.6 3.2.4.3.3.g, 3.2.1.1.2.x
Distribution Method Election is made
Computation of GloBE Income or Loss - Securitization Vehicles
2.118 Profit or loss from a securitization entity included in financial accounting net income or loss Data Point Finance/Tax June 2024 AG 6.1.2.11

20
PwC’s Pillar Two Data Input Catalog January 2025

Appendix C
Computation of
Adjusted Covered
Taxes

21
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of Adjusted Covered Taxes - Current Tax Expense
3.001 Current tax expense accrued in Financial Accounting Net Income or Loss with respect to Covered Calculation Tax MR 4.1, 4.3 3.2.4.2.b.2
Taxes for the Fiscal Year
Computation of Adjusted Covered Taxes - Blended CFC Taxes
3.002 GILTI Inclusion (including Sec. 78 Gross-up) Data Point Tax MR 4.3.2 3.2.4.4.a.5
3.003 Sec. 250 Deduction related to GILTI Inclusion Data Point Tax MR 4.3.2 3.2.4.4.a.5
3.004 FTCs utilized in GILTI basket Data Point Tax MR 4.3.2 3.2.4.4.a.5
3.005 Tested Income of each entity included in GILTI calculation Data Point Tax MR 4.3.2 3.2.4.4.a.5
Computation of Adjusted Covered Taxes - Allocation of Taxes Between Constituent Entities
3.006 Current taxes related to allocation of income/loss between main entity and flow-through entity Informational Tax June 2024 AG 5.1
3.007 Current taxes related to allocation of income/loss between main entity and PE (see below for Informational Tax June 2024 AG 3.1
cross-crediting/passive allocation)
3.008 Main Entity/CounterParty: Foreign Source Income by Basket Calculation Tax June 2024 AG 3.1.4
3.009 Main Entity: Total Tax Liability after Credits Calculation Tax June 2024 AG 3.1.3
3.010 Main Entity: Domestic Tax Liability without regard to Foreign Source Income Calculation Tax June 2024 AG 3.1.3
3.011 Main Entity: Domestic Tax Liability by Basket (foreign source) Calculation Tax June 2024 AG 3.1.3
3.012 Main Entity/Counterparty: Creditable Foreign Taxes Accrued by Basket Calculation Tax June 2024 AG 3.1.3
Computation of Adjusted Covered Taxes - Taxes on Distributions
3.013 Withholding Tax on distributed profits (transfer from recipient to payor/distributing entity) Data Point Tax MR 4.2.1(a)
3.014 Tax paid by recipient on income that is exempt under GloBE rules Data Point Tax MR 4.2.1(a)
Computation of Adjusted Covered Taxes - Eligible Distribution Tax Systems
3.015 Election - Deemed Distribution Tax Election for Eligible Distribution Tax Systems Election Tax MR 7.3.1 3.2.3.2.1
3.016 Taxes on distributed profits, deemed profit distributions, and non-business expenses imposed Data Point Tax MR 4.2.1(b), 7.3, AF 3.2.3.2.1.a.2
under an Eligible Distribution Tax System February 2023 AG 3.1
3.017 Deemed Distribution Tax Recapture Account for each Fiscal Year Calculation Tax MR 7.3.3, February 3.2.3.2.1.a.4
2023 AG 3.1
3.018 Distribution Tax that was paid in the Fiscal Year on actual and deemed distributions Calculation Tax MR 7.3.3, February 3.2.3.2.1.a.3
2023 AG 3.1
3.019 Reduction to the Recapture Account Loss Carry-forward based on the Disposition Recapture Calculation Tax MR 7.3.3, 7.3.4, 3.2.3.2.1.a
Ration under Article 7.3.4 February 2023 AG 3.3
3.020 GloBE loss in the jurisdiction Calculation Tax MR 7.3.3, February
2023 AG 3.2
Computation of Adjusted Covered Taxes - Taxes on Distributions
3.021 Tax imposed in lieu of corporate income tax, including Withholding Tax on interest and royalties Data Point Tax MR 4.2.1(c)
(to the extent not included above)
3.022 Disqualified Refundable imputation tax Data Point Tax MR 4.2.2(d)
Computation of Adjusted Covered Taxes - Adjustments for OCI
3.023 Taxes paid but booked in equity or OCI Data Point Tax MR 4.1.1

22
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of Adjusted Covered Taxes - Election - Realisation Principle
3.024 Revaluation Method Gain (Loss) - OCI - Current Taxes Data Point Tax MR 6.3.4 3.2.4.3.3.h
3.025 Tax effect for the use of the Revaluation Method (if realisation method is elected) Calculation Tax MR 3.2.5
3.026 Tax booked in P&L due to realisation (if realisation method is elected) Data Point Tax MR 3.2.5
3.027 Taxes paid upon realisation of gains (if realisation method is elected) Data Point Tax MR 3.2.5
3.028 Taxes booked in P&L because of lower depreciation (if realisation method is elected) Data Point Tax MR 3.2.5
Computation of Adjusted Covered Taxes - Election - Equity Investment Foreign Exchange Hedge
3.029 Taxes on hedging gains/losses related to excluded equity investments in the case that the Data Point Finance/Tax February 2023 AG
Foreign Exchange Hedge on Excluded Equity Gain or Loss election is made 2.3.2, MR 3.2.1(c)
Computation of Adjusted Covered Taxes - Above the Line Taxes
3.030 Covered tax accrued as expense Data Point Tax MR 4.1.2(a) 3.2.4.2.a.3.a
Computation of Adjusted Covered Taxes - Uncertain Tax Positions
3.031 Amount of tax expense related to Uncertain Tax Positions Calculation Tax MR 4.1.3(d) 3.2.4.2.a.3.i
3.032 Amount of UTP previously excluded and paid in the current year (excluding interest & penalties) Data Point Tax MR 4.1.2(c) 3.2.4.2.a.3.c
3.033 Amount of interest and penalties included in the UTP payment above Data Point Tax MR4.1.2(c) 3.2.4.2.a.3.c
Computation of Adjusted Covered Taxes - Banking or Oil and Gas
3.034 Taxes or surcharges on specific activities such as banking or exploration of oil and gas Data Point Tax MR 4.2.1
Computation of Adjusted Covered Taxes - Qualified Refundable Tax Credits & Non-Qualifying Tax Credits
3.035 Amount of Qualified Refundable Tax Credit accrued as a reduction of tax expense Data Point Tax MR 4.1.2(d) 3.2.4.2.a.3.d
3.036 Amount of Marketable Transferable Tax Credit accrued as a reduction of tax expense Data Point Tax MR 4.1.2(d) 3.2.4.2.a.3.d
3.037 Non-Qualified Refundable Tax Credit not treated as a reduction to current tax expense Data Point Tax MR 4.1.3(b) 3.2.4.2.a.3.g
3.038 Any portion of Marketable Transferable Tax Credit treated as income that does not meet the legal Calculation Tax MR 4.1.2(d) 3.2.4.2.a.3.d
transferability and marketability standards
3.039 Tax credit or refund of Covered Tax, except for any QRTC or MTTC, that was not treated as a Data Point Tax MR 4.1.3(c) 3.2.4.2.a.3.h
reduction of tax expense 4.1.3(a)
3.040 Covered Taxes refunded or credited, except for any Qualified Refundable Tax Credit, to a Data Point Tax MR 4.1.3(c) 3.2.1.2.a.2.h,
Constituent Entity that was not treated as an adjustment to current tax expense in the financial 3.2.4.2.a.3.h
accounts
Computation of Adjusted Covered Taxes - Income or Loss under Chapter 3
3.041 Current tax related to excluded income or loss under Chapter 3 - other than taxes on distribution Data Point Tax MR 4.1.3(a) paragraph 3.2.4.2.a.3.f
paid by paying or receiving entity. 8
Computation of Adjusted Covered Taxes - Election - Election - Realisation Principle
3.042 Revaluation Method Gain (Loss) - OCI - Deferred Taxes Data Point Tax MR 6.3.4 3.2.4.3.3.h
Computation of Adjusted Covered Taxes - Election - Fair Value Recognition
3.043 Fair Value Recognition Adjustment - Current Taxes Data point Tax MR 6.3.4 3.2.4.3.3.h

23
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of Adjusted Covered Taxes - International Shipping Income Exclusion
3.044 Current Taxes on international shipping income Data Point Tax MR 4.1.3(a) paragraph 3.2.4.4.a.12
9
3.045 Current Taxes on qualified ancillary international shipping income Data Point Tax MR 4.1.3(a) paragraph 3.2.4.4.a.12
9
Computation of Adjusted Covered Taxes - Taxes on Distributions
3.046 Tax on dividends that are received from a significant minority (e.g. 25%) investment in a Data Point Tax MR 4.1.3(a)
corporation/partnership (e.g., CIT on portfolio shareholdings - not dividends withholding tax)
Computation of Adjusted Covered Taxes - Current Tax Expense
3.047 Amount of current tax expense accrued (not expected) to be paid within 3 years Data Point Tax MR 4.1.3(e) 3.2.4.2.a.3.j
3.048 All current tax accrual amounts included in Covered Taxes in year T-3 that have not been paid by Data Point Tax MR 4.1.3(e)
the end of the current Fiscal Year
3.049 All current tax accrual amounts included in Covered Taxes that have not been paid within three Calculation Tax MR 4.6.1
years in excess of 1M EUR per year per jurisdiction
Computation of Adjusted Covered Taxes - Election - Debt Release Exclusion
3.050 Current tax expense related to qualifying debt release (if elected) Data Point Tax February 2023 AG 2.4
Computation of Adjusted Covered Taxes - Election - Aggregate Asset Gain
3.051 Current taxes related to Aggregate Asset Gain (if elected in current year) Data Point Tax MR 3.2.6(a) 3.2.4.2.a.3.l
Computation of Adjusted Covered Taxes - Interest and Penalties
3.052 Interest related to Covered Taxes Data Point Tax MR 4.1.2
3.053 Penalties related to taxes Data Point Tax MR 4.1.2
Computation of Adjusted Covered Taxes - Insurance Company Specific Adjustments
3.054 Taxes paid by an insurance company with respect to returns to policyholders Data Point Tax MR 4.2.2(e) 3.2.4.1.a.3.s
Computation of Adjusted Covered Taxes - Pillar Two Top-up Tax
3.055 IIR Top-up Tax included in income tax expense of parent CE Data Point Tax MR 4.2.2(a) 3.4.1.3.1.c
3.056 Qualified Domestic Top-up tax included in income tax expense Data Point Tax MR 4.2.2(b) 3.3.1.e
3.057 UTPR taxes included in income tax expense Data Point Tax MR 4.2.2(c) 3.3.4.2
Computation of Adjusted Covered Taxes - Qualified Flow-through Tax Benefits of Qualified Ownership Interests
3.058 Qualified Flow-through Tax Benefits of Qualified Ownership Interests (QOI) Informational Tax February 2023 AG 2.92 3.2.1.2.a.2.e,
3.2.4.2.a.3.e
3.059 Amortization Method for Qualified Ownership Interest Informational Tax February 2023 AG
2.9.2; June 2023 AG
2.45
3.060 Amount of tax credits that have flowed through to the owner from the Qualified Ownership Interest Calculation Tax February 2023 AG 3.2.3.1.b.4
2.92, June 2023 AG
2.45
3.061 Amount of tax-deductible losses that have flowed through to the owner from the Qualified Calculation Tax February 2023 AG 2.92 3.2.3.1.b.4
Ownership Interest multiplied by the statutory rate applicable to the owner
3.062 Distributions to the owner from the Qualified Ownership Interest Calculation Tax February 2023 AG 2.92 3.2.3.1.b.4
3.063 Proceeds from sale for all or part of a Qualified Ownership Interest Calculation Tax February 2023 AG 2.92 3.2.3.1.b.4
3.064 Current year increases from Qualified Ownership Interest Calculation Tax MR 4.6.1 3.2.3.1.b.3

24
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Computation of Adjusted Covered Taxes - Post-Filing Adjustments
3.065 Post-filing adjustments (i.e. adjusted after the return with respect to that year was filed) Data Point Tax MR 4.6 3.2.1.2.a.2.k,
3.2.4.2.a.3.k
3.066 Post filing adjustments - increase in tax liabilities in current FY Data Point Tax MR 4.6.1 3.2.1.2.a.2.k,
3.2.4.2.a.3.k
3.067 Post filing adjustments - increase in tax liabilities in prior years Data Point Tax MR 4.6.1 3.2.1.2.a.2.k,
3.2.4.2.a.3.k
3.068 Post filing adjustments - decrease in tax liabilities that are greater than 1M EUR per jurisdiction Data Point Tax MR 4.6.1 3.2.1.2.a.2.k,
per year (material decreases) 3.2.4.2.a.3.k
Computation of Adjusted Covered Taxes - Election - Immaterial Decrease in Covered Tax
3.069 Post filing adjustments - decrease in tax liabilities that are less than 1M EUR per jurisdiction per Data Point Tax MR 4.6.1 3.2.1.2.a.2.k,
year (immaterial decreases) 3.2.4.2.a.3.k
Computation of Adjusted Covered Taxes - Deferred Tax Adjustment (Article 4.4)
3.070 Deferred tax expense accrued in financial accounts Data Point Tax MR 4.4.1 3.2.4.2.c.2
3.071 Deferred tax on items excluded from the computation of GloBE Income or Loss (Chapter 3) Calculation Tax MR 4.4.1(a) paragraph 3.2.4.2.c.3.a
3

June 2024 AG 1.2.1.24,

1.2.1.33
3.072 Fair Value Recognition Adjustment - Deferred Taxes Data point Tax MR 6.3.4 3.2.4.3.3.h
3.073 Deferred Taxes on international shipping income Data Point Tax MR 4.1.3(a) paragraph
9
3.074 Deferred Taxes on qualified ancillary international shipping income Data Point Tax MR 4.1.3(a) paragraph
9
3.075 DTA on stock-based compensation booked at vest with respect to jurisdictions that have elected Data Point Tax MR 3.2.2
to use the tax deduction
3.076 Deferred tax movement related to pension expense accruals Data Point Tax MR 3.2.1 (i)
3.077 DTA related to equity gain or loss subject to the Equity Investment Inclusion Election (if not Data Point Tax MR 4.1.3 (a) 3.2.4.2.c.3.a
booked in OCI)
3.078 Deferred taxes related to fair value revaluation gain/(loss) Data Point Tax MR 3.2.1
Subject to Realization Method Election (zeroed out IF election is made)
3.079 Deferred Taxes recorded in equity or Other Comprehensive Income (OCI) Data Point Tax June 2024 AG 1.2.1.24
3.080 Deferred tax related to a GloBE loss of a permanent establishment Data Point Tax MR 4.3.4 3.2.4.2.b
3.081 Deferred taxes related to allocation of income/loss between main entity and flow-through entity Informational Tax MR 4.3.2(a), 4.3.4 &
3.4.5, June 2024 AG
4.2.3
3.082 Deferred taxes related to allocation of income/loss between main entity and permanent Informational Tax MR 4.3.2(a), 4.3.4 &
establishments (see below for cross-crediting/passive allocation) 3.4.5; June 2024 AG
4.2.3
3.083 Main Entity/CounterParty: Deferred Tax Expense by Basket (pre-foreign tax credit) Calculation Tax June 2024 AG 4.2.3
3.084 Main Entity/CounterParty: Relevant Creditable Foreign Taxes by Basket Calculation Tax June 2024 AG 4.2.3
3.085 Main Entity/Counterparty: Prior year Deferred Tax Allocated from Main Entity to Counterparty Calculation Tax June 2024 AG 4.2.3
(Passive only)

25
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
3.086 Main Entity: Domestic tax loss applied against foreign source income (current year) in which a Calculation Tax MR 4.4.1(e), February 3.2.4.2.c.3.g
recapture mechanism applies to offset future domestic income/tax liability (Substitute Loss 2023 AG 2.8
Carryforward DTA)
June 23024 AG 4.1
3.087 Election - Exclusion of Allocation of Deferred Tax Expense between Constituent Entities (other Election Tax June 2024 AG 4.2.3
than flow-through)
3.088 Deferred tax related to Eligible Distribution Tax Regime Data Point Tax MR 7.3, 4.3 3.2.4.2.c.3
3.089 Deferred tax impact of Qualified Flow-through Tax Benefits for Qualified Ownership Interests Data Point Tax February 2023 AG 2.92 3.2.4.2.c.3
(QOI)
3.090 Deferred tax adjustment for securitization entities Data Point Finance/Tax June 2024 AG 6.1.2.13
3.091 Deferred taxes in the (Insurance) Investment Entity related to Undistributed Earnings Data Point Tax MR 7.5.1 3.2.4.2.c.3
3.092 Deferred tax expense which relates to uncertain tax positions Calculation Finance/Tax/ MR 4.4.1(b) 3.2.4.2.c.3.d
FP&A
3.093 Election - Unclaimed Accrual Election (relates to DTL) Election Tax MR 4.4.2, 4.4.7 3.2.4.3.2.b

June AG 2024 1.2.7.50

3.094 Deferred tax expense with respect to unclaimed accruals Data Point Tax MR 4.4.7 3.2.4.2.c.3.c,
3.2.2.1.b.1.c
3.095 Amount of Recaptured Deferred Tax Liability determined in a preceding FY which has been paid Data Point Tax MR 4.4.2(b) 3.2.4.2.c.3.i,
during the FY 3.2.2.1.b.1.i
3.096 Amount of any Disallowed Accrual or Unclaimed Accrual paid during the current FY Data Point Tax MR 4.4.2(a) 3.2.4.2.c.3.h,
3.2.2.1.b.1.h
3.097 Valuation allowance/derecognition on DTA accrual/DTA attributable to current year losses Data Point Tax MR 4.4.1(c) 3.2.4.2.c.3.d
recognized in Deferred Tax (release or accrual)
3.098 Domestic tax rate changes Calculation Tax MR 4.4.1(d) 3.2.4.2.c.3.e
3.099 Elimination of remeasurement from the year it was accrued if the domestic tax rate is reduced Calculation Tax MR 4.6.2 3.2.4.2.c.3.k
below the Minimum Rate and the reduction in DTL in excess of 1M EUR

3.100 Election - Immaterial Decrease in Covered Tax as it relates to deferred remeasurement if the Election Tax MR 4.6.2 3.2.3.1.a.1.b
domestic rate is below the Minimum Rate

3.101 Amount of DTL increase due to a remeasurement if the domestic tax rate originally below the Calculation Tax MR 4.6.3 3.2.4.2.c.3.l
Minimum Rate increases above the Minimum Rate. The DTL increase (ie. DTE) should be
eliminated. This is in the year of remeasurement.
3.102 Re-measurement with respect to a change in the applicable domestic tax rate (rate increases Calculation Tax MR 4.6.3 3.2.4.2.c.3.l
from a percentage below 15%) - in the year of release - include the DTL increase previously
eliminated
3.103 Generation and use of tax credits as well as related deferred tax expense, except for tax credits Data Point Tax MR 4.4.1(e) 3.2.4.2.c.3.f
on the opening balance sheet of the Transition Year (the first year Pillar Two applies to a
jurisdiction)
3.104 Tax credits on the Pillar Two deferred tax opening balance sheet of the Transition Year Data Point Tax MR 4.4.1(e) 3.2.4.2.c.3.f

26
PwC’s Pillar Two Data Input Catalog January 2025 Appendix C | Computation of Adjusted Covered Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
3.105 Deferred Tax movement related to qualifying debt release (if elected) Calculation Finance/Tax/FP February 2023 AG 2.4 3.2.4.3.2.a
&A
3.106 Loss Carry Back: release of a deemed DTA in case a current year loss can be carried back to Calculation Tax MR 4.4.2(c) 3.2.2.1.c
prior years
3.107 Current year losses with no corresponding DTA recognized Data Point Tax MR 4.4.2(c) 3.2.4.2.c.3.j
3.108 Deferred taxes related to Aggregate Asset Gain (if elected in current year) Calculation Tax MR 3.2.6(a) 3.2.4.2.a.3.l
3.109 Re-measurement with respect to DTAs with a domestic rate lower than 15% Calculation Tax MR 4.4.1
3.110 Release or expiration of DTA (not included in 'regular' Deferred Tax) Data Point Tax MR 4.4.1(c) 3.2.4.2.c.3.d
3.111 DTL not paid within the subsequent 5 years (i.e., the current year and the 4 preceding years) Calculation Tax/FP&A MR 4.4.4 3.2.2.2

June 2024 AG 1.2.1.17-

20
3.112 Recapture Exception Accrual Informational Tax MR 4.4.5
June 2024 AG 1.2.1.25
3.113 Exclusion of swinging accounts and separate tracking Informational Tax June 2024 AG 1.2.1.22
3.114 Exclusion of GL accounts that generate DTAs from aggregate DTL categories Informational Tax June 2024 AG 1.2.1.21
3.115 Aggregate DTL category - related party receivables and payables Informational Tax June 2024 AG 1.2.1.20
3.116 Aggregate DTL category - amortizable intangible assets with an accounting life of more than five Informational Tax June 2024 AG 1.2.1.20
years
3.117 Aggregate DTL category - non-amortizable intangible assets (including goodwill) Informational Tax June 2024 AG 1.2.1.20
Computation of Adjusted Covered Taxes - Election - GloBE Loss Election
3.118 Election - GloBE Loss Election (if the special election applies, the Total Deferred Tax Adjustment Election Tax MR 4.5.1, 4.1.2(b) 3.2.3.1.a (5i)
amount does not apply)
3.119 Total Deferred Tax Adjustment Amount under Article 4.4 Calculation Finance/Tax MR 4.5.2 3.2.4.2.c.4
3.120 Amount of GloBE DTA accrued (current year GloBE Loss multiplied by 15%) Data Point Tax MR 4.5.3 3.2.4.2.a.3.b
3.121 Amount of GloBE DTA utilized (addition to Adjusted Covered Taxes) Data Point Tax MR 4.5.3, 4.1.2(b) 3.2.4.2.a.3.b
Computation of Adjusted Covered Taxes - Election - Excess Negative Tax Election
3.122 Election - Excess Negative Tax Election (GloBE loss jurisdictions only) Election Tax Feb 2023 AG 2.7 3.2.3.1.a.1.d
3.123 Excess negative Adjusted Covered Taxes in the CY in the case that the Excess Negative Tax Calculation Tax Feb 2023 AG 2.7 3.2.1.2.b.2
election is made
3.124 Excess Negative Tax Carryforwards from prior year Data Point Tax Feb 2023 AG 2.7 3.2.1.2.b.1

27
PwC’s Pillar Two Data Input Catalog January 2025

Appendix D
Share & Asset
Transactions

28
PwC’s Pillar Two Data Input Catalog January 2025 Appendix D | Share & Asset Transactions

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Share & Asset Transactions - Transactions
4.001 Transactions occurring after 30 November 2021, but before commencement of first Transition Informational Finance/Tax MR 9.1.3 3.2.1.1.2.z
Year
4.002 Transactions occurring in the current (GloBE) year Informational Finance/Tax MR 9.1.3 1.3.3.a, 3.2.1.1.2.z
4.003 Transaction Date Data Point Legal MR 6.2-6.3, 9.1 3.2.1.1.2.z
4.004 Legal Form of Transaction Data Point Legal MR 6.2-6.3, 9.1 3.2.1.1.2.z
4.005 Purchase Accounting Data Point Finance MR 3.1.2, 6.2-6.3, 9.1 3.2.1.1.2.z
4.006 Taxation at Seller Data Point Tax MR 6.2-6.3, 9.1 3.2.1.1.2.z
4.007 Buyer Tax Basis Data Point Tax MR 6.2-6.3, 9.1 3.2.1.1.2.z
4.008 Deferred Accounting Data Point Finance MR 6.2-6.3, 9.1 3.2.1.1.2.z
Share & Asset Transactions - Intercompany Asset Transfers
4.009 Accounting Standard used for Asset Transfer Data Point Finance MR 6.2-6.3, 9.1 3.2.1.1.2.z
Share & Asset Transactions - Gain or Loss from Disposition of Assets & Liabilities Excluded Under Article 6.3
4.010 Gain or loss from disposition of assets and liabilities excluded under Article 6.3 Data Point Finance/ MR 3.2.1(e) 3.2.4.1.a.3.e
Controllership
4.011 Excluded qualifying disposition (gain)/loss related to disposition of assets and liabilities excluded Calculation Finance/ MR 6.3.2, 6.3.3
under Article 6.3 Controllership
4.012 Carrying value of disposing CE related to acquisition/disposition excluded under Article 6.3 Data Point Finance/ MR 6.3.2, 6.3.3
Controllership
4.013 Excluded non-qualifying disposition (gain)/loss related to disposition of assets and liabilities Calculation Finance/ MR 6.3.2, 6.3.3
excluded under Article 6.3 Controllership
4.014 If acquisition/disposition is not part of a GloBE Reorganisation, gain or loss from disposing CE Calculation Finance/ MR 6.3.1
Controllership
4.015 If acquisition/disposition is not part of a GloBE Reorganisation, carrying value of acquiring CE Data Point Finance/ MR 6.3.1
Controllership
4.016 Current taxes related to excluded qualifying disposition (gain)/loss from the disposition of assets Calculation Tax MR 6.3.1
and liabilities under Article 6.3, excluded from Adjusted Covered Taxes
4.017 Current taxes related to excluded non-qualifying disposition (gain)/loss from the disposition of Calculation Tax MR 6.3.1
assets and liabilities under Article 6.3, excluded from Adjusted Covered Taxes
4.018 Current taxes related to excluded (gain)/loss from the disposition of assets and liabilities not part Calculation Tax MR 6.3.1
of a GloBE Reorganisation under Article 6.3, excluded from Adjusted Covered Taxes
4.019 Deferred taxes related to excluded qualifying disposition (gain)/loss from the disposition of assets Data Point Tax MR 6.3.1
and liabilities under Article 6.3, excluded from Adjusted Covered Taxes
4.020 Deferred taxes related to excluded non-qualifying disposition (gain)/loss from the disposition of Data Point Tax MR 6.3.1
assets and liabilities under Article 6.3, excluded from Adjusted Covered Taxes
4.021 Deferred taxes related to excluded (gain)/loss from the disposition of assets and liabilities not part Data Point Tax MR 6.3.1
of a GloBE Reorganisation under Article 6.3, excluded from Adjusted Covered Taxes

29
PwC’s Pillar Two Data Input Catalog January 2025

Appendix E
Substance-based
Income Exclusion

30
PwC’s Pillar Two Data Input Catalog January 2025 Appendix E | Substance-based Income Exclusion

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Substance Based Income Exclusion - Substance Based Income Exclusion
5.001 Substance-based income exclusion (payroll and tangible asset carve-out) - applies by default, but Calculation Finance/HR MR 5.3.1, 3.3.2
can be opted out of per year/per jurisdiction by election July 2023 AG 3.1.1
5.002 Election - Election Not to Apply Substance-Based Income Exclusion Election Tax MR 5.3.1, 3.2.3.1.a.1.c
July 2023 AG 3.32
Substance Based Income Exclusion - Payroll
5.003 Eligible employees (including contractors) Data Point Finance/HR MR 5.3.3 3.3.2.1.1
5.004 Eligible payroll costs (total remuneration including stock-based compensation and employer-paid Data Point Finance/HR MR 5.3.3 3.3.2.1.1
social security and pension)
5.005 Eligible payroll costs capitalised and included in the eligible tangible asset carve-out base Data Point Finance/HR MR 5.3.3(a) 3.3.2.1.1
5.006 Eligible payroll costs attributable to income that is excluded in accordance with Article 3 (e.g. Data Point Finance/HR MR 5.3.3(b) 3.2.4.4.a.10
shipping)
Substance Based Income Exclusion - Tangible Assets
5.007 Eligible tangible assets - property, plant and equipment Data Point Finance MR 5.3.4(a) 3.3.2.1.3
5.008 Eligible tangible assets - property, plant and equipment: carrying value of property, including land Data Point Finance MR 5.3.4 3.3.2.1.3
and buildings, that is held for sale, for lease (see more info) or for investment - after taking into
account elimination entries in consolidation
5.009 Eligible tangible assets - property, plant and equipment: the carrying value of tangible assets used Data Point Finance MR 5.3.4 3.2.4.4.a.11
to derive income that is excluded in accordance with Article 3 (e.g., shipping)
5.010 Eligible tangible assets - natural resources Data Point Finance MR 5.3.4(b) 3.3.2.1.3
5.011 Eligible tangible assets - lessee’s right of use of tangible assets (after taking into account Data Point Finance MR 5.3.4(c) 3.3.2.1.3
elimination entries in consolidation)
5.012 Eligible tangible assets - subject to revaluation method (as for example IAS 16) Data Point Finance MR 5.3.5 3.3.2.1.3
5.013 Eligible tangible assets - license or similar arrangement from a government for the use of Data Point Finance MR 5.3.4(d) 3.3.2.1.3
immovable property or exploitation of natural resources that entails significant investment in
tangible assets
5.014 Eligible tangible assets - acquired from another entity within the MNE group Data Point Finance MR 5.3.4 3.3.2.1.3
5.015 Eligible tangible assets - acquired from a 3rd party Data Point Finance MR 5.3.4 3.3.2.1.3

31
PwC’s Pillar Two Data Input Catalog January 2025

Appendix F
Allocation of Taxes

32
PwC’s Pillar Two Data Input Catalog January 2025 Appendix F | Allocation of Taxes

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Allocation of Taxes - Employees
6.001 Number of employees of all Constituent Entities per jurisdiction that has implemented UTPR, Data Point Legal/HR MR 2.6.2(a) 2.2.1.3.b
including Permanent Establishments in jurisdiction
Allocation of Taxes - Tangible Assets
6.002 NBV of tangible assets of all Constituent Entities per jurisdiction that has implemented UTPR, Data Point Finance MR 2.6.2(a) 2.2.1.3.b
including Permanent Establishments in that jurisdiction

33
PwC’s Pillar Two Data Input Catalog January 2025

Appendix G
Transitional Safe
Harbours

34
PwC’s Pillar Two Data Input Catalog January 2025 Appendix G | Transitional Safe Harbours

Typical Data References

REF # Description Category
Owner OECD Guidance GIR
Transitional Safe Harbours - Qualified CbC Report
7.001 Qualified CbC Report Informational Tax MR 1.13.1
7.002 Profit (Loss) before Income Tax Data Point Finance/ MR 1.13.1 2.2.1.3.a.2
Controllership
7.003 Total Revenue Data Point Finance/ MR 1.13.1 2.2.1.3.a.1
Controllership
Transitional Safe Harbours - Qualified Financial Statements
7.004 Qualified Financial Statements Informational Finance/ 2022 SH 17 1.2.2.1
Controllership
7.005 Current Tax Expense (excluding taxes that are not Covered Taxes) Calculation Finance/ 2022 SH 6.1 2.2.1.3.a.3
Controllership
7.006 Deferred Tax Expense (excluding taxes that are not Covered Taxes) Calculation Finance/ 2022 SH 6.1 2.2.1.3.a.3
Controllership
7.007 Uncertain Tax Positions Data Point Finance/Tax 2022 SH 6.1 2.2.1.3.a.3
Transitional Safe Harbours - Substance Based Income Exclusion
7.008 Substance-based Income Exclusion Calculation Tax MR 5.3.1, 3.3.2
July 2023 AG 3.1.1
Transitional Safe Harbours - Special Rules & Exclusions
7.009 Special Rule for Tax Neutral UPEs Informational Finance/Tax 2022 SH 6.1 2.2.1.3.a
7.010 Profit (Loss) before Income Tax (and any associated taxes) of the UPE (if it is a flow-through or Data Point Finance/Tax 2022 SH 6.1 2.2.1.3.a.2
subject to Deductible Dividend Regime)
7.011 Amount attributable to or distributed as a result of an Ownership Interest held by a Qualified Calculation Finance/Tax 2022 SH 6.1 2.2.1.3.a
Person
7.012 Net Unrealized Fair Value Loss Calculation Finance/Tax 2022 SH 6.1 2.2.1.3.a
Transitional Safe Harbours - Purchase Price Accounting
7.013 Purchase Price Accounting in Qualified Financial Statements Data Point Finance/Tax 2022 SH 17.5,
December 2023 AG 1.3
7.014 Goodwill impairment adjustments for transactions after November 30, 2021 Data Point Finance/Tax 2022 SH 17.5, 2.2.1.3.a
December 2023 AG 1.3
Transitional Safe Harbours - Hybrid Arbitrage Arrangements
7.015 List of Hybrid arbitrage arrangements Informational Finance/Tax 2022 SH 74.25-74.31, 2.2.1.3.a
December 2023 AG 2.6
7.016 Type of hybrid arbitrage arrangements with date that arrangement was entered: Data Point Finance/Tax 2022 SH 74.25-74.31, 2.2.1.3.a
• Deduction/non-inclusion arrangement December 2023 AG 2.6
• Duplicate loss arrangement
• Duplicate tax recognition arrangement
7.017 Tested Jurisdiction's Pre-tax book income with respect to any Hybrid Arbitrage Arrangements Calculation Finance/Tax 2022 SH 74.25-74.31, 2.2.1.3.a
entered into after 15 December 2022 December 2023 AG 2.6
7.018 Tested Jurisdiction's income tax expense with respect to any Hybrid Arbitrage Arrangements Calculation Finance/Tax 2022 SH 74.25-74.31, 2.2.1.3.a
entered into after 15 December 2022 December 2023 AG 2.6
Transitional Safe Harbours - Election - Simplified Calculations Safe Harbour (for NMCE)
7.019 Election - Simplified Calculations Safe Harbour (for NMCE) Election Tax MR 8.2.1, 2.2.1.2.a
December 2023 AG 6.4

35
PwC’s Pillar Two Data Input Catalog January 2025

Appendix H Legend

36
PwC’s Pillar Two Data Input Catalog January 2025 Appendix H | Legend

Column Legend: JV - Joint Venture

Ref # - Data requirement reference number MNE - Multinational Enterprise
Description - Represents the data requirement for Pillar Two calculations. MR - Model Rules
Bolded items represent the main adjustments in the Model Rules, and the non -
OCI - Other Comprehensive Income
bolded items are the data points that are used to determine the adjustment.
OECD - Organisation for Economic Co-operation and Development
Category - Reflects the type of the data requirement (data point, out of system,
calculation). PBT - Profit Before Tax
Typical Data Owner - Reflects which cross-functional group in an organization PE - Permanent Establishment
may ‘own’ the data requirement. This will likely vary from one organization to
P&L - Profit and Loss
another and therefore serves as a general guideline only.
P2 - Pillar Two
References - Reconciliation of PwC’s data requirements to the OECD Model
Rules (or commentary where applicable) and the GloBE Information Return POPE - Partially Owned Parent Entity
Annex A1.
SH - Safe Harbours
Abbreviations and acronyms:
UPE - Ultimate Parent Entity
AG - Administrative Guidance
UTP - Uncertain Tax Position
CbCR - Country-by-Country Reports
UTPR - Undertaxed Profits Rule
CE - Constituent Entity
WHT - Withholding Tax
CFC - Controlled Foreign Company
CT - Current Tax
DIR - Directive
DT - Deferred Tax
DTA - Deferred Tax Asset
DTL - Deferred Tax Liability
ETR - Effective Tax Rate
EU - European Union
FX - Foreign Exchange
FY - Fiscal Year
GIR - GloBE Information Return
GloBE - Global Anti-Base Erosion
IIR - Income Inclusion Rule

37
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