Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 7
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TAX NEUTRALITY AND DISTRIBUTION REGIMES
PART 7-3
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ELIGIBLE DISTRIBUTION TAX SYSTEMS
A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to: (a) a specified jurisdiction that has an Eligible Distribution Tax System; and (b) each Constituent Entity of the MNE Group that is located in the jurisdiction.
7-40(2)
An election under subsection (1) is an Annual Election.
Note:
Taxes on distributed profits, deemed profit distributions and non-business expenses imposed under an Eligible Distribution Tax System are Covered Taxes (see paragraph 4-40(1)(b) ).
SECTION 7-40 DEEMED DISTRIBUTION TAX ELECTION 7-40(1)A Filing Constituent Entity for an MNE Group may make an election for the MNE Group under this subsection that applies to: (a) a specified jurisdiction that has an Eligible Distribution Tax System; and (b) each Constituent Entity of the MNE Group that is located in the jurisdiction.
7-40(2)
An election under subsection (1) is an Annual Election.
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