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 2 - Other Article 3.2 adjustments  

SECTION 3-205   ADJUSTMENT - INSURANCE COMPANY AMOUNTS CHARGED TO POLICYHOLDERS FOR TAXES PAID IN RESPECT OF RETURNS TO POLICY HOLDERS  

3-205(1)    
Subsection (2) applies if a Constituent Entity of an MNE Group is an insurance company.

3-205(2)    
In computing the 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:

(a)    exclude any amount that is charged to policyholders for Taxes paid by the Constituent Entity in respect of returns to the policyholders; and

(b)    include returns to policyholders that are not reflected in the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year, to the extent that a corresponding increase or decrease in liability to policyholders is reflected in its Financial Accounting Net Income or Loss for that Fiscal Year.