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

CHAPTER 8 - ADMINISTRATION  

PART 8-2 - SAFE HARBOURS  

Division 3 - Simplified Calculations Safe Harbour  

Subdivision C - NMCE simplified calculations  

SECTION 8-175   NMCE SIMPLIFIED CALCULATIONS  

8-175(1)    
This section applies if:

(a)    an election under subsection 8-180(2) applies in relation to a Fiscal Year and a Constituent Entity of an MNE Group; and

(b)    the Constituent Entity is an NMCE for the Fiscal Year.

8-175(2)    
This section applies for the purpose of working out whether the MNE Group meets the tests mentioned in subsection 8-155(2) for the Fiscal Year.

Simplified income calculation

8-175(3)    
Treat the NMCE ' s Total Revenue for a Fiscal Year as its GloBE Income or Loss for the Fiscal Year in the following computations:

(a)    in computing the MNE Group ' s Average GloBE Income or Loss for the jurisdiction for the Fiscal Year as mentioned in paragraph 8-160(b) (SC De minimis test);

(b)    in computing the MNE Group ' s Effective Tax Rate for the jurisdiction for the Fiscal Year as mentioned in section 8-165 (SC ETR test);

(c)    in computing the MNE Group ' s Net GloBE Income for the jurisdiction for the Fiscal Year as mentioned in section 8-170 (SC Routine profits test).

Simplified revenue calculation

8-175(4)    
Treat the NMCE ' s Total Revenue for a Fiscal Year as its revenue for the Fiscal Year in the following computations:

(a)    in computing the MNE Group ' s GloBE Revenue for a Fiscal Year mentioned in paragraph 5-110(3)(a) ;

(b)    as a result of paragraph (a) , in computing the MNE Group ' s Average GloBE Revenue for a Fiscal Year as mentioned in paragraph 8-160(a) (SC De minimis test).

Simplified tax calculation

8-175(5)    
Treat the NMCE ' s Income Tax Accrued (Current Year) for a Fiscal Year as its Adjusted Covered Taxes for the Fiscal Year in computing the MNE Group ' s Effective Tax Rate for the jurisdiction for a Fiscal Year as mentioned in section 8-165 (SC ETR test).