Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
CHAPTER 9
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TRANSITION RULES
PART 9-2
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TRANSITIONAL RELIEF FOR THE SUBSTANCE-BASED INCOME EXCLUSION
SECTION 9-35
9-35
TRANSITIONAL RELIEF FOR TANGIBLE ASSET CARVE-OUT AMOUNT
For the purposes of working out the Tangible Asset Carve-out Amount for a Constituent Entity of an MNE Group located in a jurisdiction, for a Fiscal Year, under section 5-65 , treat the reference to 5% in paragraph 5-65(1)(c) as a reference to the percentage specified in the following table:
For the purposes of working out the Tangible Asset Carve-out Amount for a Constituent Entity of an MNE Group located in a jurisdiction, for a Fiscal Year, under section 5-65 , treat the reference to 5% in paragraph 5-65(1)(c) as a reference to the percentage specified in the following table:
| Tangible Asset Carve-out Amount transitional percentages | ||
| Item | If the Fiscal Year begins in: | the percentage specified is: |
| 1 | 2023 | 8.0% |
| 2 | 2024 | 7.8% |
| 3 | 2025 | 7.6% |
| 4 | 2026 | 7.4% |
| 5 | 2027 | 7.2% |
| 6 | 2028 | 7.0% |
| 7 | 2029 | 6.6% |
| 8 | 2030 | 6.2% |
| 9 | 2031 | 5.8% |
| 10 | 2032 | 5.4% |
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