Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 2 - LIABILITY AMOUNTS  

PART 2-3 - IIR OFFSET MECHANISM  

SECTION 2-20   IIR OFFSET MECHANISM  

2-20(1)    
A Parent Entity of an MNE Group ' s Allocable Share of the Top-up Tax of a Low-Taxed Constituent Entity is reduced if:

(a)    the Parent Entity holds an Indirect Ownership Interest in the Low-Taxed Constituent Entity through an Intermediate Parent Entity or a Partially-Owned Parent Entity of the MNE Group; and

(b)    the Intermediate Parent Entity or a Partially-Owned Parent Entity is not eligible for an exclusion under subsection 2-5(5) , or an equivalent law of a non-Australian jurisdiction.

2-20(2)    
The amount of the reduction is the portion of the Parent Entity ' s Allocable Share of the Top-up Tax that is brought into charge by the Intermediate Parent Entity or the Partially-Owned Parent Entity under a Qualified IIR.