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
In computing the Adjusted Covered Taxes for a Fiscal Year of the Constituent Entities of an MNE Group that are located in a jurisdiction, exclude the amount of Taxes mentioned in paragraph 4-40(1)(b) paid in relation to actual or deemed distributions by those Constituent Entities during the Fiscal Year, to the extent this amount is applied under paragraph 7-55(4)(a) .
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 7-70 7-70 DISTRIBUTION TAXES EXCLUDED IN ADJUSTED COVERED TAXESIn computing the Adjusted Covered Taxes for a Fiscal Year of the Constituent Entities of an MNE Group that are located in a jurisdiction, exclude the amount of Taxes mentioned in paragraph 4-40(1)(b) paid in relation to actual or deemed distributions by those Constituent Entities during the Fiscal Year, to the extent this amount is applied under paragraph 7-55(4)(a) .
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