Recomputes the OECD GloBE Article 5.5 permanent de minimis exclusion from per-year figures the caller supplies. Article 5.5.2 averages GloBE Revenue and GloBE Income or Loss of a jurisdiction across the current and the two preceding Fiscal Years; Article 5.5.1 then requires, conjunctively, that Average GloBE Revenue is less than EUR 10 million AND Average GloBE Income or Loss is a loss or less than EUR 1 million. A GloBE Loss year enters the average as a signed negative amount, never coerced to zero (Article 5.5.3(b), Commentary paragraphs 84 and 91). This is a different rule from the transitional CbCR safe-harbour de minimis test (a single-year test already computed by art-456), and this node does not recompute that test.
GloBEPillar TwoArticle 5.5De Minimis ExclusionZero PIIClient-side only
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Scope & reliance
Verify-only: this node recomputes a declared arithmetic test and reports whether inputs match or diverge from the stated thresholds. It states no filing conclusion and gives no tax advice; a deemed-zero result is a computed outcome on declared inputs, not a determination of what is due or owed. Short Fiscal Years are annualised by the caller before amounts reach this node; euro conversion is the caller's; the Article 5.5.4 exclusion of Stateless Constituent Entities and Investment Entities is applied upstream and taken here as a caller declaration. Source: OECD GloBE Model Rules, December 2021, Article 5.5.1–5.5.4, and the Commentary to the GloBE Model Rules, March 2022, paragraphs 79–96. No formal correctness proof exists for this node yet; see the proof-status note below the results.
Article 5.5 · Policy Parameters
election_made: the Article 5.5.1 Annual Election was made by the Filing Constituent Entity
stateless_and_investment_entities_excluded: Article 5.5.4 amounts excluded upstream, as declared
This node ships compute_proof_ready: deferred. No formal correctness proof has been produced for this kernel; the result above is a deterministic recompute, verified by a property-test floor against the OECD's own worked Example 5.5.2-1, not a proven one.