Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 4
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COMPUTATION OF ADJUSTED COVERED TAXES
PART 4-4
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MECHANISM TO ADDRESS TEMPORARY DIFFERENCES
If there is Recaptured Deferred Tax Liability for a Constituent Entity of an MNE Group located in a jurisdiction for a Fiscal Year: (a) for the purposes of section 4-20 , treat the amount of the Recaptured Deferred Tax Liability as increasing the Reduction to Covered Taxes of the Constituent Entity for the fifth preceding Fiscal Year; and (b) recalculate the Effective Tax Rate and Jurisdictional Top-up Tax of the MNE Group for the jurisdiction for the fifth preceding Fiscal Year in accordance with section 5-95 .
Note:
The Total Deferred Tax Adjustment Amount is added to Adjusted Covered Taxes under paragraph 4-5(b) .
SECTION 4-100 4-100 EFFECT OF RECAPTURED DEFERRED TAX LIABILITYIf there is Recaptured Deferred Tax Liability for a Constituent Entity of an MNE Group located in a jurisdiction for a Fiscal Year: (a) for the purposes of section 4-20 , treat the amount of the Recaptured Deferred Tax Liability as increasing the Reduction to Covered Taxes of the Constituent Entity for the fifth preceding Fiscal Year; and (b) recalculate the Effective Tax Rate and Jurisdictional Top-up Tax of the MNE Group for the jurisdiction for the fifth preceding Fiscal Year in accordance with section 5-95 .
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