GloBE Article 9.1 Transition Deferred Tax Tracker

Recomputes the OECD GloBE Article 9.1 transition recast of pre-regime deferred tax attributes, item by item over a caller-declared array, and reports the jurisdictional roll-forward total. Article 9.1.1's lower-of rule is applied as a cap: an attribute already recorded at or below the lower of the Minimum Rate and its domestic rate is left where it is. The one path on which a recast rises above the recorded figure is Article 9.1.1's third sentence: 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 date; each excluded item is reported with a named code and contributes exactly zero, never merely dropped. Article 9.1.3 recasts a qualifying intra-group transfer on the disposing entity's carrying value.