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 4-70  

4-70   AMOUNTS ACCRUED IN FINANCIAL ACCOUNTS OF CONSTITUENT ENTITY-OWNER ON DISTRIBUTION FROM CONSTITUENT ENTITY TO CONSTITUENT ENTITY-OWNER - ALLOCATION TO CONSTITUENT ENTITY  
An amount in respect of Covered Taxes for a Fiscal Year is allocated from a Constituent Entity-owner of a Constituent Entity to the Constituent Entity if the amount is:

(a)    accrued in the financial accounts of the Constituent Entity-owner for the Fiscal Year; and

(b)    so accrued in respect of distributions or deemed distributions during the Fiscal Year from the Constituent Entity to the Constituent Entity-owner that arise from the direct Ownership Interests that it holds in the Constituent Entity.