Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 7
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TAX NEUTRALITY AND DISTRIBUTION REGIMES
PART 7-2
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ULTIMATE PARENT ENTITY SUBJECT TO DEDUCTIBLE DIVIDEND REGIME
SECTION 7-35
7-35
MEANING OF DEDUCTIBLE DIVIDEND
A distribution by a Constituent Entity of an MNE Group that is subject to a Deductible Dividend Regime is a Deductible Dividend if either of the following apply: (a) it is a distribution of profits to the holder of an Ownership Interest in the Constituent Entity that is deductible from the taxable income of the Constituent Entity under the laws of the jurisdiction in which it is located; (b) if the Constituent Entity is a Cooperative - it is a patronage dividend to a member of the Cooperative.
A distribution by a Constituent Entity of an MNE Group that is subject to a Deductible Dividend Regime is a Deductible Dividend if either of the following apply: (a) it is a distribution of profits to the holder of an Ownership Interest in the Constituent Entity that is deductible from the taxable income of the Constituent Entity under the laws of the jurisdiction in which it is located; (b) if the Constituent Entity is a Cooperative - it is a patronage dividend to a member of the Cooperative.
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