Taxation (Multinational - Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026 (F2026L00908)

Schedule 1   Amendments

Part 2   Amendments relating to the Substitute Loss Carry-forward DTA

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

9   Subsection 4-90(4)

Repeal the subsection, substitute:

(4) In computing the relevant deferred tax expense mentioned in subsection (3), take account of the reversal of the Substitute Loss Carry-forward DTA only to the extent that:

(a) if the Substitute Loss Carry-forward DTA arises under subsection 4-95(1) - the foreign tax credit that gave rise to the Substitute Loss Carry-forward DTA is used to offset tax liability on income included in the Constituent Entity's GloBE Income or Loss; or

(b) if the Substitute Loss Carry-forward DTA arises under subsection 4-95(2) or (3) - the recharacterisation of income mentioned in that subsection increases the foreign tax credits used to offset tax liability on income included in the Constituent Entity's GloBE Income or Loss.