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

CHAPTER 5 - COMPUTATION OF EFFECTIVE TAX RATE  

PART 5-1 - DETERMINATION OF EFFECTIVE TAX RATE  

Note:

In computing amounts under Parts 5-1 , 5-2 , 5-3 and 5-4 , special rules apply for MNE Groups which have any of the following:

(a) a Minority-Owned Constituent Entity: see sections 5-120 and 5-125 ;

(b) a Joint Venture (and any JV Subsidiaries): see section 6-75 ;

(c) an Investment Entity or Insurance Investment Entity: see sections 7-100 and 7-115 , and Parts 7-5 and 7-6 .

SECTION 5-15   MEANING OF NET GloBE INCOME AND NET GloBE LOSS  

5-15(1)    
If, for an MNE Group for a jurisdiction for a Fiscal Year, the amount computed in accordance with the formula in subsection (2) :

(a)    is a positive amount - the Net GloBE Income of the MNE Group for the jurisdiction for the Fiscal Year is that amount; or

(b)    is zero or a negative amount - the Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year is the absolute value of that amount.

5-15(2)    
For the purposes of subsection (1) , the formula is as follows:

GloBE Income of all Constituent Entities − GloBE Losses of all Constituent Entities

where:

GloBE Income of all Constituent Entities
is the sum of the GloBE Income for the Fiscal Year of all Constituent Entities of the MNE Group located in the jurisdiction.

GloBE Losses of all Constituent Entities
is the sum of the GloBE Losses for the Fiscal Year of all Constituent Entities of the MNE Group located in the jurisdiction.