GloBE Article 9.1 Transition Deferred Tax Tracker

Recomputes the OECD GloBE Article 9.1 transition recast of pre-regime deferred tax attributes for one jurisdiction, item by item over a bounded array, and reports the jurisdictional roll-forward total. Article 9.1.1's lower-of rule is applied as a cap, so an attribute already recorded at or below the lower of the Minimum Rate and the applicable domestic tax rate is left where it is; the one path on which a recast rises is Article 9.1.1's third sentence, where a deferred tax asset recorded below the Minimum Rate is taken at the Minimum Rate on a caller-declared GloBE Loss demonstration. Article 9.1.2 exclusions apply only where a declared limb holds and the attribute arose strictly after the cut off, each reported with a named code and contributing exactly zero rather than being dropped. Article 9.1.3 recasts a qualifying intra group transfer on the disposing entity's carrying value. Rates, the cut off date, the Transition Year start and the exclusion set are versioned policy parameters, never kernel constants. Verify only: characterization, the GloBE Loss demonstration and the separate Grace Period determination all stay with the filer.

Tool URL: https://ainumbers.co/chaingraph/kernels/art-636-globe-transition-deferred-tax-tracker.kernel.mjs