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

CHAPTER 3 - COMPUTATION OF GloBE INCOME OR LOSS  

PART 3-2 - ADJUSTMENTS TO DETERMINE GloBE INCOME OR LOSS  

Division 1 - Article 3.2.1 adjustments  

SECTION 3-15  

3-15   ADJUSTMENT - NET TAXES EXPENSE  
In computing a Constituent Entity ' s GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to reverse any debits or credits in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year in respect of the following:

(a)    Covered Taxes (including Covered Taxes on income that is excluded in computing the GloBE Income or Loss);

(b)    to the extent it is not included in paragraph (a) , a deferred tax asset attributable to a loss for the Fiscal Year;

(c)    IIR;

(d)    Qualified Domestic Minimum Top-up tax;

(e)    UTPR;

(f)    Disqualified Refundable Imputation Tax;

(g)    Tax paid or accrued by an insurance company in respect of returns to policyholders to the extent that 3-205 applies in relation to those taxes.