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 3-80   ADJUSTMENT - QUALIFIED DEBT RELEASE AMOUNT  

3-80(1)    
Subsection (2) applies if an election under subsection (3) applies to:

(a)    a Constituent Entity of an MNE Group; and

(b)    a Fiscal Year.

3-80(2)    
In computing the Constituent Entity ' s GloBE Income or Loss for the Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude each qualified debt release amount of the Constituent Entity for the Fiscal Year.

Election

3-80(3)    
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to a specified Constituent Entity of the MNE Group.

3-80(4)    
An election under subsection (3) is an Annual Election.