Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 5
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COMPUTATION OF EFFECTIVE TAX RATE
PART 5-2
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TOP-UP TAX
For purposes of this Chapter, treat each Stateless Constituent Entity as a single Constituent Entity located in a separate jurisdiction.
Note:
The Jurisdictional Top-up Tax or the Top-up Tax Percentage of an MNE Group for a jurisdiction may be modified by Part 8-2 (Safe harbours).
SECTION 5-45 5-45 TREATMENT OF STATELESS CONSTITUENT ENTITIESFor purposes of this Chapter, treat each Stateless Constituent Entity as a single Constituent Entity located in a separate jurisdiction.
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