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

CHAPTER 7 - TAX NEUTRALITY AND DISTRIBUTION REGIMES  

PART 7-3 - ELIGIBLE DISTRIBUTION TAX SYSTEMS  

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 7-45  

7-45   MEANING OF ELIGIBLE DISTRIBUTION TAX SYSTEM  
An Eligible Distribution Tax System is a corporate income tax system that:

(a)    generally imposes an income tax on the amount of the profits, or certain non-business expenses, of a corporation only on or after the time that the corporation:

(i) distributes those profits to its shareholders; or

(ii) is deemed to distribute those profits to its shareholders; or

(iii) incurs those expenses; and

(b)    imposes Tax at a rate equal to or in excess of the Minimum Rate; and

(c)    was in force on or before 1 July 2021.