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 4-60  

4-60   MEANING OF BLENDED CFC TAX REGIME  
A Blended CFC Tax Regime of a jurisdiction means a Controlled Foreign Company Tax Regime under which:

(a)    the tax liability of an owner located in the jurisdiction is determined by reference to an aggregate of the income, losses and creditable taxes of other Entities, located in one or more other jurisdictions, in which the owner holds an Ownership Interest; and

(b)    the lowest rate that, if it were the corporate tax rate applicable in the one or more jurisdictions in which the other Entities are located, would result in the tax charge in those jurisdictions being sufficient to prevent a tax charge on the owner under the Controlled Foreign Company Tax Regime in respect of its share of the income of the other Entities for a Fiscal Year, is less than the Minimum Rate; and

(c)    income of Entities located in the jurisdiction in which the owner is located is not taken into account.