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

CHAPTER 4 - COMPUTATION OF ADJUSTED COVERED TAXES  

PART 4-3 - ALLOCATION OF COVERED TAXES FROM ONE CONSTITUENT ENTITY TO ANOTHER CONSTITUENT ENTITY  

SECTION 4-45  

4-45   ALLOCATION OF AMOUNTS FROM CONSTITUENT ENTITY TO PERMANENT ESTABLISHMENT - GENERAL RULE  
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity of an MNE Group (the Main Entity ) to a Permanent Establishment, if the amount is:

(a)    accrued in the financial accounts of the Main Entity, or of another Constituent Entity, for the Fiscal Year; and

(b)    so accrued in respect of the GloBE Income or Loss of the Permanent Establishment for the Fiscal Year.